New Delhi [India],
In the clarification, CBDT emphasized that the circular especially addresses the PPT provision in Indian DTAAs where such a provision exists.
The PPT is a provision used in the International Tax Act, especially to prevent misuse of the tax treaty, in the context of dual taxation privacy agreements (DTAA). PPT is designed to ensure that tax treaties are not used for artificial or deprived arrangements aimed at achieving tax benefits without real economic substances.
This further clarified that the circular DTAAS does not affect or interact with other provisions, such as inviting the rhetoric eligibility or treaty benefits.
Additionally, CBDT confirmed that the guidance provided in circular number 01/2025 does not interfere with the rules of anti-misuse under the Indian Domestic Law, including the Anti-General-General misuse rules (GAAR), specific anti-darup utilization rules (SAAR), or Judicial Abuse Rules (JAAR).
These Anti-Anti-Anti-provisions will continue to function independently of the circular.
Explanation also emphasized that the circular does not introduce any new legal interpretations. Instead, it again confirms that its gratitude is limited to the PPT provision, ensuring stability in the interpretation of tax laws without changing other sections of the Income Tax Act.
The move is expected to bring more certainty for taxpayers and tax authorities equally, especially those who deal with international taxation cases under India’s tax treaties. (AI)
This report has been auto-generated from Ani News Service. ThePrint does not have any responsibility for its content.