No bar Under OECD to provide document relied to Appellant; Mere showing of document not sufficient

High Court held that to say that the person being prosecuted or proceeded against can only be ‘shown’ such documents, but not provided copies thereof is untenable even on a plain reading of Article 26 (2) of the OECD Model Convention. 1. The short point involved in these petitions is that neither of the Petitioners has been furnished with the copies of the documents relied upon in the Show Cause Notice (SCN) issued to them by the Respondents. Both the petitioners seek copies of the documents and their statements referred to in the SCN to enable them to file a reply to the SCN. 2. T...