[ compiled answer ]
law as at 14 Aug 2026 · settled
Treaty or the Income-tax Act — which applies to a non-resident?
The compiled answer
Whichever is more beneficial to the assessee — s.90(2): the Act's provisions apply to the extent they are more beneficial, so a treaty-entitled taxpayer takes the better of the two regimes (Azadi Bachao Andolan, SC 2003), subject to s.90(2A)'s GAAR override and s.90(4)'s TRC gateway.
Pinpoint
s.90(2), Income-tax Act 1961
String-verified quote
“more beneficial to that assessee”
source: reading:in_us_liability — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/s90_2_more_beneficial.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)