Entry into force of a tax treaty depends on reciprocal notification, triggering staggered application to income and capital. Each Contracting State must notify the other upon completion of domestic procedures and the Convention enters into force on the first day of the second month after receipt of the later notification; it applies in India to income and capital for fiscal years and year end holdings beginning on or after the first April following the calendar year of entry into force, and in France to income and capital for calendar years or accounting periods beginning on or after the first January following that calendar year. The Convention also terminates the 1969 India-France double taxation agreement when its corresponding provisions become effective.
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Provisions expressly mentioned in the judgment/order text.
Entry into force of a tax treaty depends on reciprocal notification, triggering staggered application to income and capital.
Each Contracting State must notify the other upon completion of domestic procedures and the Convention enters into force on the first day of the second month after receipt of the later notification; it applies in India to income and capital for fiscal years and year end holdings beginning on or after the first April following the calendar year of entry into force, and in France to income and capital for calendar years or accounting periods beginning on or after the first January following that calendar year. The Convention also terminates the 1969 India-France double taxation agreement when its corresponding provisions become effective.
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