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Case Law Details

Case Name : Shinhan Bank Vs Deputy Director of Income Tax (International Taxation) (ITAT Mumbai)
Related Assessment Year : 2007-08
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Shinhan Bank Vs Deputy Director of Income Tax (International Taxation) (ITAT Mumbai)

S.90 : Double taxation relief-Foreign Company-discrimination allowed-Company has not made prescribed arrangement-DTAA-India -Korea. [S. 2(22A), Art. 25(1)]

We find that, by Finance Act 2001, an Explanation (now known as Explanation 1) was inserted below Section 90, and it was with retrospective effect i.e. effective 1st April 1962. This Explanation states that “For the removal of doubts,

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