Assessing Officer (International Taxation) v. Nestle SA
458 ITR 756Supreme Court of India2023#855 most cited
What is Assessing Officer (International Taxation) v. Nestle SA authority for?
The benefit of a Most Favoured Nation (MFN) clause in a Double Taxation Avoidance Agreement (DTAA) is available only upon notification by the Government. A notification under section 90(1) is a necessary and mandatory condition for giving effect to a DTAA or any protocol that alters existing law.
122
judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2023 to 2025.
Also referred to as
Nestle SA · Assessing Officer v Nestle SA · 458 ITR 756 · 155 Taxmann.com 384 · SC · Most Favoured Nation Clause · MFN Clause · section 90(1) · notification · DTAA
Also reported as
155 Taxmann.com 384
