https://www.taxtmi.com/caselaws?id=790184 Treaty residency under the India-US DTAA requires sequential application of the Article 4(2) tie-break tests, including permanent home and centre of vital interests. Although the assessee was resident and ordinarily resident under domestic law, the available material did not adequately establish immediate family circumstances, personal connections, or economic links in India and the US. Reliable information on the spouse's income component and other relevant indicators was also unavailable. Because the factual record was insufficient to determine the centre of vital interests conclusively, treaty residency required fresh factual examination by the Assessing Officer after providing 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 requires sequential application of the Article 4(2) tie-break tests, including permanent home and centre of vital interests. Although the assessee was resident and ordinarily resident under domestic law, the available material did not adequately establish immediate family circumstances, personal connections, or economic links in India and the US. Reliable information on the spouse's income component and other relevant indicators was also unavailable. Because the factual record was insufficient to determine the centre of vital interests conclusively, treaty residency required fresh factual examination by the Assessing Officer after providing 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