MLI Without Notification Is A Dead Letter How the Sky High Leasing, Kosi Aviation and Sunflower Aircraft Rulings Redefine -The Nestle SA Ripple Effect on India's 90+ MLI-Covered Treaties

MLI Without Notification Is A Dead Letter How the Sky High Leasing, Kosi Aviation and Sunflower Aircraft Rulings Redefine -The Nestle SA Ripple Effect on India's 90+ MLI-Covered Treaties https://www.taxtmi.com/article/detailed?id=16303 The article argues that MLI modifications, including the Principal Purpose Test, require a specific section 90(1) notification before they can operate in India. It relies on Nestle SA to state that treaty benefits and treaty modifications do not become enforceable merely through ratification, and it treats recent ITAT rulings as applying that principle to aircraft-leasing disputes and other MLI provisions. It also says a CBDT circular cannot cure the notification gap and proposes consolidated notifications with synthesised treaty texts. en-us Wed, 29 Apr 2026 08:25:19 +0530 Wed, 29 Apr 2026 08:25:19 +0530 TaxTMI RSS Generator MLI Without Notification Is A Dead Letter How the Sky High Leasing, Kosi Aviation and Sunflower Aircraft Rulings Redefine -The Nestle SA Ripple Effect on India's 90+ MLI-Covered Treaties https://www.taxtmi.com/article/detailed?id=16303 The article argues that MLI modifications, including the Principal Purpose Test, require a specific section 90(1) notification before they can operate in India. It relies on Nestle SA to state that treaty benefits and treaty modifications do not become enforceable merely through ratification, and it treats recent ITAT rulings as applying that principle to aircraft-leasing disputes and other MLI provisions. It also says a CBDT circular cannot cure the notification gap and proposes consolidated notifications with synthesised treaty texts. Articles Income Tax Wed, 29 Apr 2026 08:25:19 +0530 https://www.taxtmi.com/article/detailed?id=16303