https://www.taxtmi.com/caselaws?id=789167 Treaty residence was determined under the tie-breaker rule because the taxpayer was treated as resident in both States under domestic law; on the facts, closer personal and economic relations and work performance in Kazakhstan established treaty residence there, so salary for the overlapping period was taxable only in Kazakhstan. Rental income from immovable property in London was taxable only in the State where the property was situated and was not taxable in India. Dividend income from the Netherlands was remanded for fresh adjudication with foreign tax credit directions. Interest income was taxable at the beneficial treaty rate of 10% once Kazakhstan treaty residence was ed. en-us Wed, 25 Feb 2026 00:00:00 +0530 Sat, 04 Apr 2026 08:53:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789167 Treaty residence was determined under the tie-breaker rule because the taxpayer was treated as resident in both States under domestic law; on the facts, closer personal and economic relations and work performance in Kazakhstan established treaty residence there, so salary for the overlapping period was taxable only in Kazakhstan. Rental income from immovable property in London was taxable only in the State where the property was situated and was not taxable in India. Dividend income from the Netherlands was remanded for fresh adjudication with foreign tax credit directions. Interest income was taxable at the beneficial treaty rate of 10% once Kazakhstan treaty residence was ed. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789167