https://www.taxtmi.com/caselaws?id=759658 Where an individual has a permanent home in both contracting states, treaty residence is determined by the centre of vital interests, assessed by the closer personal and economic relations. On the facts, the assessee's prolonged stay in India, family residence there, and active involvement in an Indian company outweighed largely passive U.S. rental and investment links. The assessee was therefore treated as a resident of India under the India-USA DTAA, and the U.S.-derived income was taxable in India. en-us Thu, 03 Oct 2024 00:00:00 +0530 Fri, 04 Oct 2024 10:34:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759658 Where an individual has a permanent home in both contracting states, treaty residence is determined by the centre of vital interests, assessed by the closer personal and economic relations. On the facts, the assessee's prolonged stay in India, family residence there, and active involvement in an Indian company outweighed largely passive U.S. rental and investment links. The assessee was therefore treated as a resident of India under the India-USA DTAA, and the U.S.-derived income was taxable in India. Case-Laws Income Tax Thu, 03 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759658