Double Taxation Avoidance: treaty provisions to be given effect in India following treaty entry into force. The Central Government, under section 90 of the Income-tax Act, directs that the India-Bulgaria Convention for the avoidance of double taxation and the prevention of fiscal evasion shall be given effect in India following mutual notification of completion of domestic procedures. Article 1 specifies the Convention's Personal Scope, applying to persons who are residents of one or both Contracting States, thereby defining the resident taxpayers covered by the treaty.
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Provisions expressly mentioned in the judgment/order text.
Double Taxation Avoidance: treaty provisions to be given effect in India following treaty entry into force.
The Central Government, under section 90 of the Income-tax Act, directs that the India-Bulgaria Convention for the avoidance of double taxation and the prevention of fiscal evasion shall be given effect in India following mutual notification of completion of domestic procedures. Article 1 specifies the Convention's Personal Scope, applying to persons who are residents of one or both Contracting States, thereby defining the resident taxpayers covered by the treaty.
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