Government remuneration and pension: taxable only in the paying State for citizens serving governmental functions, subject to profit-making exception. Remuneration and pensions paid by a Contracting State or its subdivisions to its citizens for services in the discharge of governmental functions are taxable only in that State; this exclusivity does not apply to remuneration or pensions for services connected with any profit making business carried on by the Government or its subdivisions. The provision also covers payments by the Reserve Bank of India and the Bangladesh Bank.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Government remuneration and pension: taxable only in the paying State for citizens serving governmental functions, subject to profit-making exception.
Remuneration and pensions paid by a Contracting State or its subdivisions to its citizens for services in the discharge of governmental functions are taxable only in that State; this exclusivity does not apply to remuneration or pensions for services connected with any profit making business carried on by the Government or its subdivisions. The provision also covers payments by the Reserve Bank of India and the Bangladesh Bank.
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