https://www.taxtmi.com/highlights?id=99008 Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard. en-us Tue, 21 Apr 2026 17:37:54 +0530 Tue, 21 Apr 2026 17:37:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99008 Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard. Highlights Income Tax Tue, 21 Apr 2026 17:37:54 +0530 https://www.taxtmi.com/highlights?id=99008