https://www.taxtmi.com/caselaws?id=784804 Section 6(1)(c) applied because the assessee stayed in India for 141 days in the relevant year and more than 365 days in the preceding four years; Explanation 1(b) was confined to Indian citizens or persons of Indian origin on a visit to India, and Explanation 1(a) did not apply because the departure for employment occurred in an earlier year. Under Article 4 of the India-Singapore DTAA, the tie-breaker tests pointed to India: the assessee had homes in both countries, but personal and economic ties, including Indian properties, investments and business links, were closer to India. The draft assessment procedure under section 144C was treated as valid because the proposed variation was prejudicial to the assessee, while the demand computation was required to be corrected for the refund amount. en-us Fri, 09 Jan 2026 00:00:00 +0530 Mon, 12 Jan 2026 17:26:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784804 Section 6(1)(c) applied because the assessee stayed in India for 141 days in the relevant year and more than 365 days in the preceding four years; Explanation 1(b) was confined to Indian citizens or persons of Indian origin on a visit to India, and Explanation 1(a) did not apply because the departure for employment occurred in an earlier year. Under Article 4 of the India-Singapore DTAA, the tie-breaker tests pointed to India: the assessee had homes in both countries, but personal and economic ties, including Indian properties, investments and business links, were closer to India. The draft assessment procedure under section 144C was treated as valid because the proposed variation was prejudicial to the assessee, while the demand computation was required to be corrected for the refund amount. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784804