https://www.taxtmi.com/caselaws?id=415951 Treaty exemption under Article 22 of the India-U.S. Double Tax Avoidance Agreement is available only where the non-resident claimant satisfies the statutory residence-certificate requirement linked to section 90(4) of the Income-tax Act, 1961. The analysis states that treaty benefits may be invoked only to the extent they are more beneficial, but the claimant must still produce a Tax Residency Certificate from the foreign country concerned. Without a United States residence certificate, the precondition for claiming the Article 22 exemption was not met, so the treaty relief could not be granted. en-us Tue, 14 Dec 2021 00:00:00 +0530 Fri, 17 Dec 2021 08:54:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415951 Treaty exemption under Article 22 of the India-U.S. Double Tax Avoidance Agreement is available only where the non-resident claimant satisfies the statutory residence-certificate requirement linked to section 90(4) of the Income-tax Act, 1961. The analysis states that treaty benefits may be invoked only to the extent they are more beneficial, but the claimant must still produce a Tax Residency Certificate from the foreign country concerned. Without a United States residence certificate, the precondition for claiming the Article 22 exemption was not met, so the treaty relief could not be granted. Case-Laws Income Tax Tue, 14 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415951