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Income Tax - Highlights / Catch Notes

Home Highlights February 2016 Year 2016 This

Royalty u/s 9(1)(vi) read with DTAA - It is fallacious to assume ...


Domestic Law Amendments on Royalties Don't Affect Double Taxation Treaties: Misinterpretations Don't Change International Agreements.

February 13, 2016

Case Laws     Income Tax     HC

Royalty u/s 9(1)(vi) read with DTAA - It is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change - HC

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