Tax treaty application altered: domestic anti-abuse rules may apply and a foreign residence certificate is required for relief. Amendments to section 90 impose three operative changes: Chapter X-A applies even if not beneficial to the assessee; non-resident claimants must obtain a prescribed certificate of residence from the foreign government to claim treaty relief; and meanings assigned to undefined treaty terms by notifications under section 90(3) are deemed to take effect from the date the treaty came into force, with retrospective application as specified.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty application altered: domestic anti-abuse rules may apply and a foreign residence certificate is required for relief.
Amendments to section 90 impose three operative changes: Chapter X-A applies even if not beneficial to the assessee; non-resident claimants must obtain a prescribed certificate of residence from the foreign government to claim treaty relief; and meanings assigned to undefined treaty terms by notifications under section 90(3) are deemed to take effect from the date the treaty came into force, with retrospective application as specified.
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