https://www.taxtmi.com/caselaws?id=754522 Article 24 of the India-UAE DTAA exempts the Government of one Contracting State from tax on income derived from the other State. Abu Dhabi Investment Authority is expressly included within "Government" for the UAE under Article 24(2)(b)(ii). Its FPI registration, tax residency certificate, PAN, address and other records supported its identity and UAE residency. Treaty protection cannot be denied on speculative or extraneous grounds, such as a mobile-number entry or internet search result, where those records establish that the entity is the sovereign institution named in the treaty. Consequently, its interest income derived from India is exempt from Indian tax under Article 24. en-us Mon, 26 Feb 2024 00:00:00 +0530 Tue, 14 Oct 2025 11:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754522 Article 24 of the India-UAE DTAA exempts the Government of one Contracting State from tax on income derived from the other State. Abu Dhabi Investment Authority is expressly included within "Government" for the UAE under Article 24(2)(b)(ii). Its FPI registration, tax residency certificate, PAN, address and other records supported its identity and UAE residency. Treaty protection cannot be denied on speculative or extraneous grounds, such as a mobile-number entry or internet search result, where those records establish that the entity is the sovereign institution named in the treaty. Consequently, its interest income derived from India is exempt from Indian tax under Article 24. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754522