Clause 21 - Amendment of section 90

Application of Chapter X-A: provisions apply even if not beneficial to the assessee, changing treaty relief requirements.

Amendment to section 90 omits the earlier sub-section (2A) and inserts a new sub-section (2A) providing that the provisions of Chapter X-A shall apply to an assessee even if those provisions are not beneficial to the assessee, effective from the assessment period commencing in 2016-17. The amendment also inserts a new sub-section (5) stipulating that a certificate of residence in a country or specified territory outside India is necessary but not sufficient to claim relief under the relevant agreement, with retrospective effect to the earlier assessment period.