India-Spain DTAA: "Principally" Interpreted as 50% Threshold for Assets in Absence of Other Evidence.

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....Income accrued in India - DTAA between India and Spain - while the expression ‘principally’ is not specifically defined in the Indo Spanish tax treaty, as evident from the subsequent clarifications in the model convention commentaries, and in the absence of anything to suggest there was a different intention at an earlier point of time, the threshold test can be safely applied at “fifty percent” of total assets.....