Standard Chartered Bank, Mumbai vs Ddit(It) 2 (1), Mumbai on 15 March, 2024
Further,
the Appellant submit that Special Bench decision in case of
Sumitomo (supra) is not only dealing with India-Japan Tax
Treaty but also dealt with IndiaNetherland Tax Treaty. Your
Honour will appreciate that the language of India-UK Tax Treaty
(applicable in case of the Appellant) is in line with India-
Netherland Tax Treaty.