Re-defining Superiority of DTAA – Opening doors for new TP litigation – Rakesh Nangia & Amit Agarwal

The Finance Act 2017 has ushered a slew of amendments aimed at rationalizing certain provisions, reducing litigation and ushering more transparency for expanding the tax base. One such notable amendment is the insertion of ‘Explanation 4’ to both Section 90, and section 90A of the Income Tax Act, 1961 (“the Act”) that brings in more clarity with regard to the interpretation of ‘terms’ used in Double Taxation Avoidance Agreement (“DTAA” or “the Treaty” or “the Agreement”) domestic tax law.

Rakesh Nangia, Managing Partner and Amit Agarwal, Partner with inputs from Aanchal Kapoor, Associate Director contributed an article on  Re-defining Superiority of DTAA – Opening doors for new TP litigation for Taxsutra.