Personal scope

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....tion and prevention of fiscal evasion with respect to taxes on income has been ratified and the instruments of ratification exchanged at Brasilia on 11th March, 1992 as required by Article 28 of the said Convention : Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961) and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), ....

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....ents of third States), Have agreed as follows:] ARTICLE 1 PERSONAL SCOPE ^2[1.] This Convention shall apply to persons who are residents of one or both of the Contracting States. ^3[2. This Convention shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under Articles 19, 20, 21, 23, 24, 25 and 27.]     ....