https://www.taxtmi.com/caselaws?id=443228 Article 25 of the India-Oman treaty was read with Omani tax law to determine whether dividend income exempted in Oman still qualified for treaty relief. The exemption under Article 8(bis) was treated as a development-linked incentive, so tax that would have been payable but for that incentive fell within the treaty's relief framework. The taxpayer's Oman presence was treated as a permanent establishment, and the dividend income was regarded as connected with that establishment. A clarification issued by the Omani Ministry of Finance was treated as an interpretative aid, not a new source of law, and the Revenue's treaty position was sustained. en-us Fri, 15 Sep 2023 00:00:00 +0530 Wed, 28 Jan 2026 16:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443228 Article 25 of the India-Oman treaty was read with Omani tax law to determine whether dividend income exempted in Oman still qualified for treaty relief. The exemption under Article 8(bis) was treated as a development-linked incentive, so tax that would have been payable but for that incentive fell within the treaty's relief framework. The taxpayer's Oman presence was treated as a permanent establishment, and the dividend income was regarded as connected with that establishment. A clarification issued by the Omani Ministry of Finance was treated as an interpretative aid, not a new source of law, and the Revenue's treaty position was sustained. Case-Laws Income Tax Fri, 15 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443228