Yes - basically what you're implying is that there is no 'business connection' and accordingly the remittance is not taxable as per Section 9 of the Income Tax Act.
Once it is determined that there is not tax liability as per the Income Tax Act you do not need to get in to the intricacies of DTAA and accordingly TRC will not matter.
Hope this helps.
Dhruv
Once it is determined that there is not tax liability as per the Income Tax Act you do not need to get in to the intricacies of DTAA and accordingly TRC will not matter.
Hope this helps.
Dhruv