In this article, I am making an honest and sincere attempt to find a plausible, logical and well-reasoned answer to this complicated question, analysing the applicable provisions of the Constitution of India, the Income Tax Act, 1961
source https://www.caclubindia.com/articles/can-gaar-override-dtaa-46852.asp
source https://www.caclubindia.com/articles/can-gaar-override-dtaa-46852.asp
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