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Sec. 271(1)(c) constitutionally valid as penalty can be levied towards sum determined pursuant to DTAA convention

September 30, 2019[2019] 109 taxmann.com 137 (Karnataka)

INTERNATIONAL TAXATION: Section 271(1)(c) cannot be regarded as ultra vires of Constitution insofar as imposing of penalty on amounts determined pursuant to Convention for Avoidance of Double Taxation between Union of India and other Sovereign Countries which is enforced in Indian territory by section 90 and Rules made thereunder

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