[ compiled answer ]
law as at 14 Aug 2026 · judicial
Are MLI modifications enforceable in India after Sky High Leasing?
The compiled answer
Contested. India has not separately notified the MLI modifications under s.90(1) and has published no synthesised texts; Sky High Leasing (Mum ITAT 2025), extending Nestlé SA (SC 2023), holds unnotified modifications unenforceable. Any MLI-based position for Indian periods must carry both readings until the point is settled.
Pinpoint
s.90(1), Income-tax Act 1961; Sky High Leasing (Mum ITAT 2025); Nestlé SA (SC 2023)
String-verified quote
“India has not separately notified the MLI modifications u/s 90(1); the Sky High Leasing line (Mum ITAT 2025), extending Nestlé SA (SC 2023), holds unnotified modifications unenforceable.”
source: treaty-note:india_netherlands — 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/mli_sky_high_enforceability.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)