Income accrued in India - Period of stay in India - This claim of the assessee has not been rebutted or...

Income accrued in India - Period of stay in India - This claim of the assessee has not been rebutted or denied by any of the lower authorities. Both the lower authorities have simply relied upon the provisions of section 5 and section 90 to state that since the assessee was a resident and ordinarily resident in India during the year, therefore, the provisions of DTAA would not apply in the case of the assessee. However, a perusal of section 90 read with Article 16 of the DTAA would show that sec..... .....

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