Indian Tax Authority Appeals Order of Income Tax Appellate Tribunal that MLI Modifications Must be Formally Notified to Apply

According to recent reports, the Indian tax authority has formally submitted its appeal before the High Court against the consolidated order issued in August 2025 by the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) regarding the application of BEPS MLI to India's tax treaties. As previously reported, one of the key outcomes of the order was the ITAT's finding that the Principal Purpose Test (PPT) provisions under Articles 6 and 7 of the BEPS Multilateral Instrument (MLI) are not …