OECD
Notification under Section 90(1) of Income Tax Act mandatory for giving effect to a DTAA or protocol: Supreme Court
“Upon India entering into a treaty or protocol does not result in its automatic enforceability in courts and tribunals; the provisions of such treaties and protocols do not therefore, confer rights upon parties, till such time, as appropriate notifications are issued, in terms of Section 90(1).”
Green Finance and Environmental Governance
by Kritika Krishnamurthy† and Tapasi Mohapatra††