Resident – Limited Liability Company : Where assessee, a Limited Liability Company (LLC) incorporated in USA, claimed to be a resident of USA and offered to tax income by way of receipts on account of fees at rate of 15 per cent, applying rate given in India-USA DTAA, since assessee was liable to tax in resident State by virtue of US Income-tax Law, it qualified as a ‘person’ under Article 4 of Indo-US Tax Treaty and, thus, it was eligible for treaty benefit – General Motors Company USA v. ACIT, Circle International Taxation 1(3)(1) – [2024] 166 taxmann.com 170 (Delhi – Trib.)
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