Delhi High Court in case of (Director of Income Tax Versus New Skies Satellite BV, Shin Satellite Public Co. Ltd. - 2016 (2) TMI 415 - DELHI HIGH COURT)
held that in case of 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
held that in case of 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
No comments:
Post a Comment