Held that higher rate of tax prescribed for foreign company is not to be regarded as violation of non-discriminatory clause, i.e., article 26 of DTAA between India-France. Appeal of assessee is dismissed. (AY. 2021-22)
BNP Paribas. v. ACIT (2024) 207 ITD 532 (Mum) (Trib.)
S. 90 :Double taxation relief-Rate applicable to domestic companies-Non-discrimination clause-Higher rate of tax prescribed for foreign company is not to be regarded as violation of non-discriminatory clause, i.e., article 26 of DTAA between India-France. [Art. 26]
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