India: DENIAL OF TAX TREATY BENEFITS- ARE GRANDFATHERED INVESTMENTS FAIR GAME?

A recent ruling by the Authority for Advance Rulings (AAR) in the case of Bidvest has stirred the proverbial hornets' nest when it comes to the issue of treaty protection, and has reignited the debate of substance over form when it comes to availing the benefits of a tax treaty. ... - Continue reading