In the result, the appeal filed by the assessee stands allowed
Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()
Section 2(47) of the Act), (b) the consequent tax on the capital gain accrued to MA/GIMD, is clearly and exclusively allocated to France under the provisions of Article 14(5) of the DTAA (c) retrospective amendments to provisions of the Act (by the Finance Act, 2012) per se do not operate to deflect, modify, or subject DTAA provisions