https://www.taxtmi.com/circulars?id=65389 The MFN clause permits importing a lower rate or restricted source taxation scope from a later India-third State treaty into an earlier India-OECD State treaty only if the third State was an OECD member when India concluded the later treaty, the later treaty was concluded after signature/entry into force of the earlier treaty as required by the MFN wording, India limited its taxing rights in the later treaty for the relevant income items, and India issues the required domestic notification implementing the treaty benefit; unilateral foreign decrees lacking bilateral consultation are not binding on India. en-us Thu, 03 Feb 2022 00:00:00 +0530 Fri, 04 Feb 2022 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=65389 The MFN clause permits importing a lower rate or restricted source taxation scope from a later India-third State treaty into an earlier India-OECD State treaty only if the third State was an OECD member when India concluded the later treaty, the later treaty was concluded after signature/entry into force of the earlier treaty as required by the MFN wording, India limited its taxing rights in the later treaty for the relevant income items, and India issues the required domestic notification implementing the treaty benefit; unilateral foreign decrees lacking bilateral consultation are not binding on India. Circulars Income Tax Thu, 03 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/circulars?id=65389