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CA Final · Direct Tax Laws & International Taxation · Double Taxation Relief

Kiran Pvt Ltd, a non-resident, uses a term in a treaty that is defined neither in the treaty nor in the Income-tax Act, 2025 nor in any notification under section 159(7)(b). Under section 159(7)(c), the term is understood, unless the context otherwise requires, as having the meaning given in:

Such a term takes its meaning from any Central Government Act related to taxes. Failing that, it takes its meaning from any other law of the Central Government. Section 159(7)(c) applies this where the term is undefined in the treaty, the Act and any notification, and it has effect from the date the agreement came into force.

  1. Aany Act of the Central Government related to taxes, and in any other case in any other law of the Central GovernmentCorrect
  2. Bthe law of the country of Kiran Pvt Ltd's residence
  3. Cthe OECD Model Convention commentary only
  4. Dthe Income-tax Rules, 2026 alone

Explanation

Section 159(7)(c) provides a fallback for undefined terms. The meaning is taken from any Central Government Act relating to taxes, and in any other case from any other Central Government law. It takes effect from the date the agreement came into force. The foreign country's law and the OECD commentary are not named in the section.

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