Section 159 - Agreement with foreign countries or specified territories and adoption by Central Government of agreement between specified associations for double taxation relief.
Income-tax Act, 2025 Part B Double taxation relief
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Double taxation relief: treaty adoption and agreement provisions allow treaty terms to benefit taxpayers over less favourable domestic provisions. Section 159 authorises the Central Government to enter into, and to adopt agreements between specified associations and foreign counterparts, for granting relief from double taxation, preventing treaty-shopping and tax evasion, exchanging information for prevention or investigation of tax avoidance, and recovering tax. Where a notified agreement applies, provisions of the Act shall govern to the extent they are more beneficial to the assessee, subject to the continued application of Chapter XI; non-residents must produce a residency certificate and prescribed documents to claim relief.
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.
Double taxation relief: treaty adoption and agreement provisions allow treaty terms to benefit taxpayers over less favourable domestic provisions.
Section 159 authorises the Central Government to enter into, and to adopt agreements between specified associations and foreign counterparts, for granting relief from double taxation, preventing treaty-shopping and tax evasion, exchanging information for prevention or investigation of tax avoidance, and recovering tax. Where a notified agreement applies, provisions of the Act shall govern to the extent they are more beneficial to the assessee, subject to the continued application of Chapter XI; non-residents must produce a residency certificate and prescribed documents to claim relief.
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