Double taxation treaty applies to residents, implemented through domestic tax law to give the convention effect. The Convention for the avoidance of double taxation and prevention of fiscal evasion between India and Trinidad and Tobago is given effect in India under section 90 of the Income-Tax Act; it entered into force after completion of the Contracting States' notification procedures and its provisions are to be applied in the Union of India. Article 1 prescribes that the Convention applies to persons who are residents of one or both Contracting States, making residency the operative criterion for treaty coverage.
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Provisions expressly mentioned in the judgment/order text.
Double taxation treaty applies to residents, implemented through domestic tax law to give the convention effect.
The Convention for the avoidance of double taxation and prevention of fiscal evasion between India and Trinidad and Tobago is given effect in India under section 90 of the Income-Tax Act; it entered into force after completion of the Contracting States' notification procedures and its provisions are to be applied in the Union of India. Article 1 prescribes that the Convention applies to persons who are residents of one or both Contracting States, making residency the operative criterion for treaty coverage.
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