Tax treaty applicability: domestic rule makes Chapter X-A apply even if not beneficial and mandates residency certificate. Section 90A is amended to make Chapter X-A applicable even if not beneficial to the assessee, to require a prescribed residency certificate from the foreign government before a non-resident may claim relief under an agreement, and to deem meanings assigned by in-force notifications to terms used in agreements to have effect from the date the agreement came into force.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty applicability: domestic rule makes Chapter X-A apply even if not beneficial and mandates residency certificate.
Section 90A is amended to make Chapter X-A applicable even if not beneficial to the assessee, to require a prescribed residency certificate from the foreign government before a non-resident may claim relief under an agreement, and to deem meanings assigned by in-force notifications to terms used in agreements to have effect from the date the agreement came into force.
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