Tax treaty definitions clarify residency, taxable persons, enterprises, national status and competent authority roles under the DTAA. Defines key terms for the India-Bhutan tax treaty: territorial scope of each State; 'person', 'company' and 'enterprise' as taxable units; 'enterprise of a Contracting State' by residence; 'international traffic' tied to place of effective management; the competent authority in each State; 'national' for individuals and legal persons; 'tax' limited to Indian or Bhutanese taxes excluding penalties; and fiscal/income year definitions for India and Bhutan, with undefined terms adopting domestic tax-law meanings.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify residency, taxable persons, enterprises, national status and competent authority roles under the DTAA.
Defines key terms for the India-Bhutan tax treaty: territorial scope of each State; "person", "company" and "enterprise" as taxable units; "enterprise of a Contracting State" by residence; "international traffic" tied to place of effective management; the competent authority in each State; "national" for individuals and legal persons; "tax" limited to Indian or Bhutanese taxes excluding penalties; and fiscal/income year definitions for India and Bhutan, with undefined terms adopting domestic tax-law meanings.
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