2018 (4) TMI 1799

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... rosion of tax base in the country, the Transfer Pricing provisions would apply and in this context, whether the Tribunal was correct in applying such provisions repelling the assessee's contention? (2) Whether on the facts and circumstances of the case and in law, the Tribunal was right in holding that the benefit under Article 9(1) of the India Netherlands tax treaty read with Section 90 o .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ntention? (2) Whether on the facts and circumstances of the case and in law, the Tribunal was right in holding that the benefit under Article 9(1) of the India Netherlands tax treaty read with Section 90 of the Indian Income Tax Act, 1961 is not available to the appellant? Learned counsel Shri Varun Patel waived service of notice of admission of appeals on behalf of the department. - - T .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X