Personal scope of tax treaty: residents of one or both Contracting States covered; treaty incorporated into domestic law. The Central Government notifies that the India-France Convention for avoidance of double taxation and prevention of fiscal evasion is in force and shall be given effect in India under domestic tax statutes. Article 1 sets the Convention's personal scope, providing that it applies to persons who are residents of one or both Contracting States, thereby making residency the governing criterion for the treaty's applicability.
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Provisions expressly mentioned in the judgment/order text.
Personal scope of tax treaty: residents of one or both Contracting States covered; treaty incorporated into domestic law.
The Central Government notifies that the India-France Convention for avoidance of double taxation and prevention of fiscal evasion is in force and shall be given effect in India under domestic tax statutes. Article 1 sets the Convention's personal scope, providing that it applies to persons who are residents of one or both Contracting States, thereby making residency the governing criterion for the treaty's applicability.
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