Personal scope of tax treaty: residence-based application determines which persons fall within treaty coverage. Notification directs implementation in India of the Convention between India and Italy for the avoidance of double taxation and prevention of fiscal evasion, following exchange of instruments of ratification; Article 1 defines the personal scope by applying the Convention to persons who are residents of one or both Contracting States, establishing residence as the connecting factor for treaty coverage.
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Provisions expressly mentioned in the judgment/order text.
Personal scope of tax treaty: residence-based application determines which persons fall within treaty coverage.
Notification directs implementation in India of the Convention between India and Italy for the avoidance of double taxation and prevention of fiscal evasion, following exchange of instruments of ratification; Article 1 defines the personal scope by applying the Convention to persons who are residents of one or both Contracting States, establishing residence as the connecting factor for treaty coverage.
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