https://www.taxtmi.com/caselaws?id=176388 A treaty-based notification implementing an amended India-FRG double taxation arrangement could not be applied retrospectively to impose tax on fees for technical services and related payments for periods before it came into force, because a delegated notification cannot create a new tax burden on accrued rights unless the treaty itself authorises retrospective effect; the earlier exemption position was also protected by promissory estoppel. The project study payment addition was likewise unsustainable on the reasoning already applied in connected matters, so the addition was deleted. en-us Wed, 17 Jun 1998 00:00:00 +0530 Mon, 21 Dec 2015 15:55:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176388 A treaty-based notification implementing an amended India-FRG double taxation arrangement could not be applied retrospectively to impose tax on fees for technical services and related payments for periods before it came into force, because a delegated notification cannot create a new tax burden on accrued rights unless the treaty itself authorises retrospective effect; the earlier exemption position was also protected by promissory estoppel. The project study payment addition was likewise unsustainable on the reasoning already applied in connected matters, so the addition was deleted. Case-Laws Income Tax Wed, 17 Jun 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176388