DTAA cannot be overridden by a unilateral legislative amendment by one Country

CIT (IT)­ Vs Reliance Infocomm Ltd (Bombay High Court)

Mere amendments in the Act would not over­ride the provisions of Double Tax Avoidance Agreement (DTAA). It was held that: on a final note, India’s change in position to the OECD Commentary cannot be a fact that influences the interpretation of the words defining royal

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