The Indian Central Board of Direct Taxes issued Notification No. 39/2012 dated 17 September 2012 introducing a new rule in the Income Tax Rules 1962 in relation to a Tax Residence Certificate (TRC). The new Rule prescribes the manner in which a non-resident can present a TRC in order to claim relief under an applicable tax treaty. It states that the TRC obtained by a non-resident from its res…