Tax residency under DTAA: persons resident in one or both contracting states fall within the treaty's scope and benefits. The Central Government, under section 90 of the Income-tax Act, has directed that the Convention for avoidance of double taxation and prevention of fiscal evasion on income and capital gains be given effect in India. Article 1 specifies the Convention's personal scope: it applies to persons who are residents of one or both of the Contracting States, defining who may claim treaty benefits and be subject to its rules.
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Provisions expressly mentioned in the judgment/order text.
Tax residency under DTAA: persons resident in one or both contracting states fall within the treaty's scope and benefits.
The Central Government, under section 90 of the Income-tax Act, has directed that the Convention for avoidance of double taxation and prevention of fiscal evasion on income and capital gains be given effect in India. Article 1 specifies the Convention's personal scope: it applies to persons who are residents of one or both of the Contracting States, defining who may claim treaty benefits and be subject to its rules.
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