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of <h1>Gujarat HC Upholds Tribunal Decision on Transfer Pricing & Tax Treaty Benefits</h1> <h3>Shell Global Solutions International B.V. Versus Deputy Director Of Income Tax</h3> The Gujarat HC upheld the Tribunal's decision, ruling in favor of the respondent on the interpretation of Transfer Pricing provisions and the benefits ... TP Adjustment - India Netherlands tax treaty - HELD THAT:- Tax appeals are admitted for consideration of the following substantial questions of law :- (1)Whether in the facts and circumstances of the case, the assessee was correct in contending that there being no erosion 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 of the Indian Income Tax Act, 1961 is not available to the appellant? The Gujarat High Court admitted tax appeals to consider substantial questions of law related to Transfer Pricing provisions and the applicability of benefits under the India Netherlands tax treaty. The Tribunal's decision on these matters was challenged by the appellant.
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