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2015 (1) TMI 239 - HC - Income TaxDTAA between India and Portugal - Effect of amendment on 30.08.1999 made under Notification No. S.O. 693 (E) Held that:- A provision has been incorporated in the Indo-Netherlands DTAC by virtue of paragraph 5 of Article 12 of the same, whereby the very same make available clause, which is to be found in the DTAA between India and USA read with the memorandum of understanding connected therewith, has been incorporated into Indo-Netherlands convention by way of amendment on 30.08.1999, by notification No. S.O. 693 (E) - it is evident that the Authority for Advance Rulings had not considered the amendment thus, the Ruling cannot stand thus, it is set aside and the matter is remitted back to the AAR for fresh consideration Decided in favour of assessee.
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