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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-based scope: treaty applies to persons resident in either or both Contracting States, defining tax applicability.</h1> The Convention governs persons who are residents of one or both Contracting States, establishing the personal scope for taxes on income and capital. The Central Government notified the Convention and directed that its provisions be given effect in India under the relevant statutory powers.

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