OECD commentary cannot be used to deny DTAA benefits

HIGH COURT OF BOMBAY Director of Income-tax, (International Taxation) Versus Chiron Bearing Gmbh & Co. IT APPEAL NO. 2273 OF 2010 JANUARY 8, 2013 JUDGMENT M.S. Sanklecha, J. This appeal by the revenue challenges the order dated 04.07.2008 of the Income Tax Appellate Tribunal (the Tribunal) relating to the Assessment Year 2002-03. 2. Though, the appeal has formulated five questions of law, only following two questions of law are pressed by the revenue for consideration of this court. (a) Whether on the facts and in the circumstances of the case and in law was the Tribunal ...