Double taxation avoidance agreement applies to residents of the Contracting States and governs tax treatment from the agreed fiscal year. The India-Bhutan Double Taxation Avoidance Agreement, notified under section 90 of the Income-tax Act, applies to residents of one or both Contracting States and is to be given effect in India; its provisions operate for income derived in fiscal years beginning on or after the first fiscal year following the Agreement's entry into force, per the Agreement's temporal clause.
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Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance agreement applies to residents of the Contracting States and governs tax treatment from the agreed fiscal year.
The India-Bhutan Double Taxation Avoidance Agreement, notified under section 90 of the Income-tax Act, applies to residents of one or both Contracting States and is to be given effect in India; its provisions operate for income derived in fiscal years beginning on or after the first fiscal year following the Agreement's entry into force, per the Agreement's temporal clause.
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