Currently for DTAA, “Resident means a person liable to tax by reason of his domicile, residence, place of management or any other criterion of a similar nature”

Now Country can make their laws either to impose no tax (A) on all person (B) a certain class of person (C) certain source of income

As per Azadi Bachao Andolan (SC), all persons covered by situation-A or B or C are entitled to benefit of DTAA.

So current ”liability to tax” included not only the present liability but also potential future liability to tax.

New law propose country following option(A) policy I.e. no tax on all person, India will not give DTAA benefit

SO all non-residents of the country covered in (A) having any income in the financial year 2020-21 will not get DTAA benefit