Residence-based scope: treaty applies to persons resident in one or both Contracting States, defining coverage under the DTAA. The Convention establishes a bilateral framework to avoid double taxation and prevent fiscal evasion with respect to taxes on income and capital, and the Central Government has directed that its provisions be given effect in India under the Income Tax Act and Companies (Profits) Surtax Act; Article 1 specifies that the Convention applies to persons who are residents of one or both Contracting States.
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.
Residence-based scope: treaty applies to persons resident in one or both Contracting States, defining coverage under the DTAA.
The Convention establishes a bilateral framework to avoid double taxation and prevent fiscal evasion with respect to taxes on income and capital, and the Central Government has directed that its provisions be given effect in India under the Income Tax Act and Companies (Profits) Surtax Act; Article 1 specifies that the Convention applies to persons who are residents of one or both Contracting States.
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