Double Taxation Avoidance — Landmark Events

Landmark Events

Azadi Bachao Andolan v. Union of India

2003

This landmark Supreme Court judgment established the supremacy of DTAA provisions over domestic tax law when the treaty provision is more beneficial to the taxpayer. The court…

Vodafone International Holdings B.V. v. Union of India

2012

The Supreme Court's decision in the Vodafone case had profound implications for DTAA interpretation and international taxation. The court held that the indirect transfer of Indian…

Ishikawajima-Harima Heavy Industries Ltd. v. Director of Income Tax

2007

This Supreme Court judgment clarified the concept of permanent establishment under DTAAs, particularly regarding construction and installation projects. The court held that the…

Morgan Stanley & Co Inc. v. Director of Income Tax

2007

This Supreme Court decision addressed the attribution of profits to permanent establishments and the application of beneficial ownership provisions in DTAAs. The court established…