{"id":744,"date":"2024-01-22T02:24:07","date_gmt":"2024-01-22T02:24:07","guid":{"rendered":"https:\/\/theleagle.in\/?p=744"},"modified":"2024-02-14T10:45:49","modified_gmt":"2024-02-14T10:45:49","slug":"leg-history-of-sec-904-905-it-act-1961","status":"publish","type":"post","link":"https:\/\/theleagle.in\/?p=744","title":{"rendered":"Leg History of Sec 90(4) & 90(5), IT Act, 1961"},"content":{"rendered":"
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The infographic below is a snapshot of the legislative history of Section 90(4) and 90(5) of IT Act, 1961. It provides a summary view of the Income Tax Department’s attempt to include a stringent condition for a non-resident assessee to claim DTAA benefits. The condition, simply stated, was that a TRC issued by a contracting state is a necessary but not a sufficient condition to claim DTAA benefits. It was supposed to allow the Indian income tax authorities to go behind the TRC issued by another state. <\/p>\n\n\n\n

The importance and relevance of the legislative history of the aforesaid provisions can be better understood by reading this<\/a> and this<\/a> in the wake of Delhi High Court’s decision involving tax benefits under the India-Singapore DTAA. An appeal against the decision is pending before the Supreme Court at the time of publishing this infographic. <\/p>\n\n\n\n\n \n