https://www.taxtmi.com/caselaws?id=399323 A substituted DTAA tax rate notified under section 90 was treated as replacing the earlier rate provision in full, so the new lower rate applied for the entire previous year and not only from the notification date. The analysis applied the principle that a substituted provision operates as a repeal of the former provision and comes into force in its place. On that basis, the assessee was entitled to the revised 10% rate for assessment year 2006-07, and the issue was resolved in favour of the assessee and against the revenue. en-us Tue, 15 Sep 2020 00:00:00 +0530 Thu, 08 Oct 2020 11:46:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399323 A substituted DTAA tax rate notified under section 90 was treated as replacing the earlier rate provision in full, so the new lower rate applied for the entire previous year and not only from the notification date. The analysis applied the principle that a substituted provision operates as a repeal of the former provision and comes into force in its place. On that basis, the assessee was entitled to the revised 10% rate for assessment year 2006-07, and the issue was resolved in favour of the assessee and against the revenue. Case-Laws Income Tax Tue, 15 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399323