pkm4
Level 2

Deductions & credits

The technical explanation of the Indo-US tax treaty says this in the fourth para of the article 22:

 

If a professor or teacher remains in the host State for more than the specified two-year period, he may be subject to tax in that State, under its law, for the entire period of his presence.
 
 
Although the article 22 of the tax treaty does not have any retroactive clause but its technical explanation makes this confusion.