In a seminal judgment, the Division Bench of the Supreme Court ruled in favor of the Revenue in a protracted and contentious dispute concerning the Most Favored Nation (MFN) clause in the tax treaties. This decision marks a significant departure from the established legal precedent. Its consequences are anticipated to reverberate extensively throughout the realm of international taxation, especially concerning the interpretation of the Double Taxation Avoidance Agreements (DTAA) and the protocols concerning DTAA.
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