https://www.taxtmi.com/caselaws?id=790184 Treaty residency under the India-US DTAA had to be determined through the Article 4(2) tie-break sequence, beginning with permanent home and then centre of vital interests. The record was incomplete on the assessee's personal and economic relations, including immediate family connections and other relevant indicators needed to assess where vital interests lay. Because the material was inadequate and unreliable for a conclusive factual finding, the residency issue could not be finally decided on the existing record. The matter was therefore remitted for fresh fact-finding and reconsideration after giving the assessee an opportunity of hearing. en-us Fri, 17 Apr 2026 00:00:00 +0530 Tue, 21 Apr 2026 08:48:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790184 Treaty residency under the India-US DTAA had to be determined through the Article 4(2) tie-break sequence, beginning with permanent home and then centre of vital interests. The record was incomplete on the assessee's personal and economic relations, including immediate family connections and other relevant indicators needed to assess where vital interests lay. Because the material was inadequate and unreliable for a conclusive factual finding, the residency issue could not be finally decided on the existing record. The matter was therefore remitted for fresh fact-finding and reconsideration after giving the assessee an opportunity of hearing. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790184