2024 (8) TMI 887

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..... rce - Most Favoured Nation (MFN) - Indian treaties with countries that are members of the Organisation for Economic Cooperation and Development ( OECD ) - protocol for changing terms or conditions in treaty - lowering of rate of taxation at source on dividends, interest, royalties or fees for technical services (hereafter FTS ) - bilateral treaties in question are between India and Netherlands, Fr .....

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..... such event, the terms of the earlier DTAA require to be amended through a separate notification under Section 90. The interpretation of the expression is has present signification. Therefore, for a party to claim benefit of a same treatment clause, based on entry of DTAA between India and another state which is member of OECD, the relevant date is entering into treaty with India, and not a later .....

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..... ) NO. 86 OF 2024 IN CIVIL APPEAL NO. 1430/2023 REVIEW PETITION (C) NO. OF 2024 (@ Diary No. 54071 of 2023) IN CIVIL APPEAL NO. 1423 OF 2023 REVIEW PETITION (C) NO. OF 2024 (@ Diary No. 54075 of 2023) IN CIVIL APPEAL NO. 1424 OF 2023 REVIEW PETITION (C) NO. OF 2024 (@ Diary No. 54076 of 2023) IN CIVIL APPEAL NO. 1426 OF 2023 REVIEW PETITION (C) NO. OF 2024 (@ Diary No. 54088 of 2023) IN CIVIL APPEA .....

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