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          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.

          <h1>Residence rules determine treaty coverage: convention applies to persons resident in one or both contracting states and is given effect.</h1> The Convention applies to persons who are residents of one or both Contracting States, thereby defining the class of persons covered by the treaty, and the Central Government has directed that all provisions of the Convention be given effect in India through domestic implementation to avoid double taxation and prevent fiscal evasion.

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