TaxTMI 
TaxTMI 
Breaking Down the Supreme Court's Decision on Double Taxation Avoidance Agreements
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....ion Avoidance Agreements (DTAAs), setting a precedent for future interpretations and applications. The case, an appeal from a decision of the High Court, underscores the intricate balance between domestic tax laws and international treaties. Background, Facts, and High Court Decision: This case originates from a dispute over the application of DTAAs in India. The High Court had previously ruled ....
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....for a broader understanding of international treaties and their automatic integration into domestic law, without the stringent requirement of a separate notification. This perspective highlighted the dynamic nature of international law and its interaction with domestic tax regulations. Statutory Provisions: At the heart of this case was Section 90(1), a crucial piece of legislation governing Ind....
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....ot;is": The Court clarified the present significance of the term "is," indicating that the benefits of a DTAA apply from the date of treaty entry with India. Implications and Impact This judgment has far-reaching implications for international taxation and treaty negotiations. It clarifies India's stance on the integration of international treaties into domestic law, potential....