Agreement and Protocol between the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income - 88/2026 - Income-Tax Act, 2025
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Principal purpose test limits India-Sri Lanka treaty benefits where arrangements seek relief contrary to treaty purpose. The India-Sri Lanka tax treaty protocol is notified for implementation and applies in India to income derived in fiscal years beginning on or after 1 April following the calendar year of its entry into force. It strengthens the treaty's anti-abuse framework by adopting a principal purpose test. Treaty benefits may be denied where obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions. The amended preamble also addresses tax evasion, avoidance and treaty shopping.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Principal purpose test limits India-Sri Lanka treaty benefits where arrangements seek relief contrary to treaty purpose.
The India-Sri Lanka tax treaty protocol is notified for implementation and applies in India to income derived in fiscal years beginning on or after 1 April following the calendar year of its entry into force. It strengthens the treaty's anti-abuse framework by adopting a principal purpose test. Treaty benefits may be denied where obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions. The amended preamble also addresses tax evasion, avoidance and treaty shopping.
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