Double Taxation Avoidance: India-Switzerland tax treaty applied domestically via government notification, defining residency-based coverage. The Central Government notified that, following completion of entry-into-force procedures, all provisions of the India-Switzerland Agreement for the avoidance of double taxation on income shall be given effect in India. Article 1 sets the Agreement's personal scope, providing that it applies to persons who are residents of one or both Contracting States, thereby defining eligibility for treaty benefits.
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Provisions expressly mentioned in the judgment/order text.
Double Taxation Avoidance: India-Switzerland tax treaty applied domestically via government notification, defining residency-based coverage.
The Central Government notified that, following completion of entry-into-force procedures, all provisions of the India-Switzerland Agreement for the avoidance of double taxation on income shall be given effect in India. Article 1 sets the Agreement's personal scope, providing that it applies to persons who are residents of one or both Contracting States, thereby defining eligibility for treaty benefits.
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