MFN clause is an integral part of DTAA and self-operational; Delhi HC sets aside decision of AAR
The High Court of Delhi held that MFN clause of the Protocol, which forms part of the India-France DTAA, automatically becomes applicable.There is no requirement to have a separate notification incorporating the beneficial provisions of the DTAA between India and UK as forming part of the India- France DTAA. Steria (India) Ltd. v. Commissioner of Income-tax-VI. [2016] 72 taxmann.com 1 (Delhi).
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