Tax treaty amendment: fiscal-year references changed to calendar year, making the DTAA effective from the calendar year's start. Amendments to the India-Ireland Double Taxation Convention replace the fiscal-year references with the calendar year and reinterpret transitional references to the next year's fiscal start as the first day of January; India accepted these textual changes by Note Verbale and the exchange of notes constitutes agreement that the Convention's temporal application shall follow the revised transitional wording from its entry into force for all taxes covered.
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.
Tax treaty amendment: fiscal-year references changed to calendar year, making the DTAA effective from the calendar year's start.
Amendments to the India-Ireland Double Taxation Convention replace the fiscal-year references with the calendar year and reinterpret transitional references to the next year's fiscal start as the first day of January; India accepted these textual changes by Note Verbale and the exchange of notes constitutes agreement that the Convention's temporal application shall follow the revised transitional wording from its entry into force for all taxes covered.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.