If effective management of company situated in Netherlands it can claim benefit under India – Netherlands treaty

 HIGH COURT OF GUJARAT Director of Income-tax (International Taxation) versus Mitsutor Shipping Agency (P.) Ltd. TAX APPEAL NO. 12 OF 2012 JULY  4, 2012 JUDGMENT N.V. Anjaria, J. The present appeal preferred by the Revenue is directed against the order dated 12th August 2011 of the Income-tax Appellate Tribunal, Rajkot Bench, Rajkot in ITA No. 26/RJT/2011 for the Assessment Year 2007-08. 2. The appellant has raised following two questions, formulated in the memorandum of appeal, as substantial question of law. “A. Whether the Appellate Tribunal is right in law and on f...