https://www.taxtmi.com/caselaws?id=763316 The tribunal condoned a 164-day delay in filing the appeal due to a communication gap. It upheld the denial of split residency benefits and exemption under Articles 4 and 16 of the India-US DTAA, determining that the income earned in the USA was taxable in India, as the center of vital interest remained in India. However, the tribunal directed the Assessing Officer to grant the assessee credit for foreign taxes paid abroad under section 90 of the Indian Income Tax Act, partially allowing the appeal to prevent double taxation. en-us Fri, 25 Oct 2024 00:00:00 +0530 Wed, 18 Dec 2024 08:58:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763316 The tribunal condoned a 164-day delay in filing the appeal due to a communication gap. It upheld the denial of split residency benefits and exemption under Articles 4 and 16 of the India-US DTAA, determining that the income earned in the USA was taxable in India, as the center of vital interest remained in India. However, the tribunal directed the Assessing Officer to grant the assessee credit for foreign taxes paid abroad under section 90 of the Indian Income Tax Act, partially allowing the appeal to prevent double taxation. Case-Laws Income Tax Fri, 25 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763316