Casenote – Decision on Application of the Non-Discrimination Article under India’s Treaty with Japan

Journal
India
Asia-Pacific Tax Bulletin 2015 (Volume 21), No. 1
This article analyses the decision of the Delhi Bench of the Indian Income Tax Appellate Tribunal on the applicability of the provisions of non-discrimination as contained in article 24 of the India-Japan Double Taxation Avoidance Agreement on payments made by resident Indian entities to Japanese entities.