For ensuring parity and uniformity In the application of the PPT provision under India’s DTAAs, it is clarified that the PPT provision is Intended to he applied prospectively. Accordingly, the PPT ...
The Central Board of Direct Taxes has issued a new guidance note on the Principal Purpose Test (PPT) for tax treaty benefits, applicable prospectively. The note ensures that grandfathering provisions ...
Provisions will continue to be governed by the specific clauses outlined in respective Double Taxation Avoidance Agreements ...