Importance of Section 90(1) Notification in DTAA: SC’s Ruling

Assessing Officer Circle (International Taxation) Vs Nestle SA (Supreme Court) Introduction: The recent Supreme Court judgment in Assessing Officer Circle (International Taxation) 2(2)(2) New Delhi Vs Nestle Sa has shed light on the necessity and mandatory condition of a notification under Section 90(1) for a court, authority, or tribunal to give effect to a Double Taxation Avoidance Agreement (DTAA) or any protocol altering its terms. In this article, we’ll delve into the key aspects of this ruling and its implications. The Case Background: The case revolved around the interpretation of...