Confirms a non-resident payee's TRC and Form 10F are on file before DTAA relief is claimed on a payment — the specific documents Sections 90(4)/90A(4) make a precondition, distinct from the payment itself.
Payer: ___ · Payee: ___, ___ · DTAA article relied on: ___
Purpose: Sections 90(4) and 90A(4) make furnishing a Tax Residency Certificate obtained from the payee's home-country government a mandatory precondition for that payee to claim DTAA relief — without it, the payee (and, practically, the payer relying on the treaty rate for TDS) cannot avail treaty benefits regardless of actual residence.
A TRC covering the wrong period (e.g. one that expired before the payment date, or one issued for a different financial/calendar year than when the income arose) does not satisfy Section 90(4)/90A(4) for that payment — verify the validity period against the actual date(s) of payment/accrual, not just that a TRC exists somewhere on file.
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