2015 (1) TMI 239

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....dan, Ruchir Bhatia and Akash Vajpai ORDER 1. This writ petition is directed against the ruling dated 09.12.2011 in AAR No.869/2010 given by the Authority for Advance Rulings. One of the pleas raised by the petitioner was that the said authority had not considered the Double Taxation Avoidance Agreement between India and Portugal which is an OECD country. The learned counsel for the petitioner su....

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....g into the Indo-Portugese DTAA, but insofar as the Indo-USA DTAA is concerned, a provision similar to that DTAA has been incorporated in the Indo-Netherlands DTAC by virtue of paragraph 5 of Article 12 of the same, whereby the very same make available clause, which is to be found in the DTAA between India and USA read with the memorandum of understanding connected therewith, has been incorporated ....