https://www.taxtmi.com/caselaws?id=255040 An advance ruling under the Indo-Netherlands tax convention was challenged because it did not consider the 30.08.1999 amendment to Article 12(5) introducing a clause comparable to the "make available" formulation. The High Court treated that amendment as a material legal development for interpreting the convention, held that the ruling could not stand in its absence, and set it aside. The matter was remitted to the Authority for Advance Rulings for fresh consideration of all issues, uninfluenced by the earlier ruling. en-us Tue, 30 Sep 2014 00:00:00 +0530 Wed, 07 Jan 2015 09:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255040 An advance ruling under the Indo-Netherlands tax convention was challenged because it did not consider the 30.08.1999 amendment to Article 12(5) introducing a clause comparable to the "make available" formulation. The High Court treated that amendment as a material legal development for interpreting the convention, held that the ruling could not stand in its absence, and set it aside. The matter was remitted to the Authority for Advance Rulings for fresh consideration of all issues, uninfluenced by the earlier ruling. Case-Laws Income Tax Tue, 30 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255040