Bibliographic record
Abstract
Courts in India have been taking a view that whenever the expression ‘may be taxed’ has been used in a tax treaty without anything else, it is the state of source that gets the exclusive taxation right and India, as the country of residence, loses the same. Recently, the Income Tax Appellate Tribunal gave a decision involving a Bollywood artist, resident in India, who had performed in Canada and from whose income, tax was withheld in Canada. The Tribunal, while interpreting the relevant tax treaty, came to the conclusion that India has no right to tax the income. According to the Tribunal, India by entering into a treaty with Canada has given away its right of taxation to Canada. This article analyses and comments on the decision; it looks at the genesis of the controversy, at previous case law and at the efforts of the Indian Revenue to deal with the issue, including the latest notification defining the expression ‘may be taxed’ issued by the Central Board of Direct Taxes.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.004 | 0.011 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.002 | 0.004 |
| Science and technology studies | 0.020 | 0.025 |
| Scholarly communication | 0.025 | 0.009 |
| Open science | 0.002 | 0.005 |
| Research integrity | 0.009 | 0.016 |
| Insufficient payload (model declined to judge) | 0.013 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".