Indo-USA DTAA Article 16(1) applies despite Indian salary if no services were rendered in India. Residential status irrelevant.

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....Residential status - resident or nonresident of India - The application of article 16(1) of Indo-USA DTAA cannot be denied to assessee merely because the salary check was paid by an Indian entity and the undisputed fact that no service was rendered by assessee for the impugned period in India. - AT....