ITAT Delhi examines Principal Purpose Test and allows the benefit under India-Luxembourg Tax Treaty

In a first of its kind ruling, the Delhi bench of the Income Tax Appellate Tribunal (ITAT) has adjudicated on the merits of the PPT provisions and in the facts, granted the benefit under the double taxation avoidance agreement (Tax Treaty) between India and Luxembourg with respect to income earned by a Luxembourg company (Taxpayer) from its India investments.