Union Of India (Uoi) And Anr. vs Azadi Bachao Andolan And Anr.

The Supreme Court examined the validity of CBDT Circular No. 789 dated 13.04.2000 concerning the assessment of income under the Indo-Mauritius Double Taxation Avoidance Convention (DTAC) 1983. The primary issue was whether the circular was ultra vires Sections 90 and 119 of the Income-tax Act, 1961. The court analyzed the interplay between domestic tax laws and international treaties intended to encourage foreign investment and prevent double taxation.