Higher tax burden on non-resident was’t discriminatory under India-France DTAA

IT/ILT: In view of order passed in case of Dy. CIT v. Sakura Bank (IT Appeal No. 1230 (Bom) of 1995 dated 31-10-2003) higher rate of tax applicable to assessee, a non-resident company, was not violative of non-discriminatory clause, i.e., article 26 of DTAA between India and France