https://www.taxtmi.com/caselaws?id=10741 The India-Malta tax treaty was interpreted by its ordinary language, and the clause on entry into force in India was found to apply only to the fiscal year beginning on or after 1 April of the year following its entry into force. The Kerala HC rejected reliance on beneficial construction, contemporaneous administrative practice, punctuation arguments, and reddendo singula singulis, holding that none could override the clear treaty text. Section 90(2) of the Income-tax Act did not displace the express treaty wording where no ambiguity existed. Treaty benefit was therefore unavailable for assessment year 1996-97 and became available only from assessment year 1997-98. en-us Wed, 01 Jun 2005 00:00:00 +0530 Fri, 24 Jul 2009 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10741 The India-Malta tax treaty was interpreted by its ordinary language, and the clause on entry into force in India was found to apply only to the fiscal year beginning on or after 1 April of the year following its entry into force. The Kerala HC rejected reliance on beneficial construction, contemporaneous administrative practice, punctuation arguments, and reddendo singula singulis, holding that none could override the clear treaty text. Section 90(2) of the Income-tax Act did not displace the express treaty wording where no ambiguity existed. Treaty benefit was therefore unavailable for assessment year 1996-97 and became available only from assessment year 1997-98. Case-Laws Income Tax Wed, 01 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10741