Categories
Taxation

Is TRC Still Conclusive? Rethinking Treaty Entitlements

Harshita Dhinwa and Ram Sundar Singh Akela Introduction The Tax Residency Certificate was never a complete answer to the question of treaty entitlement on a proper reading of a treaty text and international law. It functioned primarily as a proof of jurisdiction, but over time, institutional practice elevated it to a substantial safeguard, which was […]

Categories
Taxation

Beyond Revocability Transitional Fairness in Tax Exemption Withdrawal

Qazi Ahmad Introduction The Supreme Court recently held that the State can withdraw earlier granted Tax exemptions to industries in public interest in State of Maharashtra v. Reliance Industries Ltd. However, the case is being treated as a minor issue of a decision to withdraw a Tax exemption of electricity-duty. However, such a reading diminishes […]