India's MFN Clause: Taxation on Dividends, Interest, Royalties in Treaties Needs Section 90(1) Notification to Enforce.

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....Most Favoured Nation (MFN) - rate of taxation at source on dividends, interest, royalties or fees for technical services (hereafter ‘FTS’) - bilateral treaties in question are between India and Netherlands, France, and Switzerland, respectively - Upon India entering into a treaty or protocol does not result in its automatic enforceability in courts and tribunals; the provisions of such treaties and protocols do not therefore, confer rights upon parties, till such time, as appropriate notifications are issued, in terms of Section 90(1). - SC....