https://www.taxtmi.com/caselaws?id=441159 For treaty residence under Article 4 of the DTAA, mere ownership of a house in India did not by itself show that a permanent home was available in India. The residence enquiry had to consider the full set of connecting factors, including the family's relocation, foreign residency certificate, accommodation in Indonesia, children's schooling, insurance, bank account and employment assignment. On those facts, the assessee's habitual abode and centre of personal and economic life were in Indonesia, so the treaty tie-breaker treated him as resident there and the salary from the foreign assignment was not taxable in India to that extent. en-us Tue, 07 Mar 2023 00:00:00 +0530 Thu, 03 Aug 2023 07:54:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441159 For treaty residence under Article 4 of the DTAA, mere ownership of a house in India did not by itself show that a permanent home was available in India. The residence enquiry had to consider the full set of connecting factors, including the family's relocation, foreign residency certificate, accommodation in Indonesia, children's schooling, insurance, bank account and employment assignment. On those facts, the assessee's habitual abode and centre of personal and economic life were in Indonesia, so the treaty tie-breaker treated him as resident there and the salary from the foreign assignment was not taxable in India to that extent. Case-Laws Income Tax Tue, 07 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441159