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No tax on global income of an assessee deemed as resident of foreign country as per tie-breaker rule of DTAA

April 11, 2019[2019] 104 183 (Bangalore - Trib.)/[2019] 177 ITD 17 (Bangalore - Trib.)

INTERNATIONAL TAXATION : Where assessee succeeded in establishing that he was a resident of US under article 4 of DTAA between India and USA for period he was on Indian assignment, assessee would be entitled to treaty exemption and accordingly, his income for aforesaid period could not have been brought to tax in India

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