India-United States income tax treaty benefits apply without tax residency certificate: 

The Ahmedabad Bench of the Income-tax Appellate Tribunal held that the taxpayer cannot be denied benefits under the India-United States income tax treaty because it has not furnished a tax residency. However, the taxpayer must satisfy eligibility for the tax treaty benefit, and it is the responsibility of the taxpayer to give sufficient and reasonable evidence in support of residential status so as to satisfy the conditions under Article 4(1) of the tax treaty. The case is: Skaps Industries India Pvt Ltd.

Read a June 2018 report [PDF 735 KB]