[ compiled answer ]
law as at 14 Aug 2026 · settled
Does GAAR override a treaty election under s.90(2)?
The compiled answer
Yes — s.90(2A): Chapter X-A applies to the assessee even if its provisions are not beneficial, notwithstanding the s.90(2) election. The treaty analysis holds only while no impermissible-avoidance-arrangement declaration is in play.
Pinpoint
s.90(2A), Income-tax Act 1961
String-verified quote
“Notwithstanding anything contained in sub-section (2), the provisions of Chapter X-A of the Act shall apply”
source: reading:in_us_liability — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/gaar_overrides_treaty_election.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)