TaxBuzz – ITAT Ruling in the Case of SC Lowy

Recent ruling of the Delhi bench of Income tax Appellate Tribunal in the case of S.C. Lowy P.I. (Lux) S.A.R.L., wherein the Tribunal had examined the principal purpose test introduced by amendment in Multilateral Instruments in the India-Luxembourg tax treaty. This is the first case in India where the Tribunal had decided on the entitlement of treaty benefit to the taxpayer, post implementation of principal purpose test.