https://www.taxtmi.com/caselaws?id=432819 Salary earned in Singapore was held not taxable in India for the relevant period because treaty residence under the India-Singapore DTAA prevailed over the domestic residence test. The assessee had shifted to Singapore for employment, obtained a Singapore tax residency certificate, and was treated as resident in both States only for treaty purposes. Article 4(2) required sequential application of the tie-breaker rules-permanent home, centre of vital interests, habitual abode, and nationality-and the facts supported Singapore residence for that period. With treaty protection available under section 90(2) and the income already taxed in Singapore, the same salary could not be brought to tax again in India, so the addition was deleted. en-us Wed, 28 Dec 2022 00:00:00 +0530 Sat, 14 Jan 2023 07:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432819 Salary earned in Singapore was held not taxable in India for the relevant period because treaty residence under the India-Singapore DTAA prevailed over the domestic residence test. The assessee had shifted to Singapore for employment, obtained a Singapore tax residency certificate, and was treated as resident in both States only for treaty purposes. Article 4(2) required sequential application of the tie-breaker rules-permanent home, centre of vital interests, habitual abode, and nationality-and the facts supported Singapore residence for that period. With treaty protection available under section 90(2) and the income already taxed in Singapore, the same salary could not be brought to tax again in India, so the addition was deleted. Case-Laws Income Tax Wed, 28 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432819