Residence-based scope under DTAA applies to persons resident in one or both Contracting States, governing tax allocation. Article 1 defines the personal scope of the India-Malaysia DTAA: the Agreement applies to persons who are residents of one or both Contracting States, establishing the class of taxpayers covered by the treaty's allocation of taxing rights, avoidance of double taxation, and prevention of fiscal evasion.
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Provisions expressly mentioned in the judgment/order text.
Residence-based scope under DTAA applies to persons resident in one or both Contracting States, governing tax allocation.
Article 1 defines the personal scope of the India-Malaysia DTAA: the Agreement applies to persons who are residents of one or both Contracting States, establishing the class of taxpayers covered by the treaty's allocation of taxing rights, avoidance of double taxation, and prevention of fiscal evasion.
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