Country who is party to a Treaty cannot unilaterally alter its provisions

IN THE ITAT MUMBAI BENCH ‘L’ WNS North America Inc. Versus Assistant Director of Income-tax (International Taxation) IT APPEAL NO. 8621 (MUM.) OF 2010 [ASSESSMENT YEAR 2006-07] DECEMBER 14, 2012 ORDER R.S. Syal, Accountant Member  This appeal by the assessee is directed against the order passed by the Assessing Officer on 28.10.2010 u/s 144C(13) read with section 143(3) of the Income-tax Act, 1961 (hereinafter called the ‘Act’) in relation to the assessment year 2006-2007. 2.1. First issue raised in this appeal is against the holding the Marketing and...