The Delhi Income Tax Appellate Tribunal (ITAT) issued an order on 30 December 2024 concerning the eligibility of a Luxembourg company to the benefits of 2008 India-Luxembourg tax treaty as impacted by the BEPS MLI. The case involved SC Lowy P.I. (LUX) S.A.R.L., a Luxembourg-based subsidiary of a Cayman Islands holding company. The Luxembourg company invested in Indian bonds and pass-through certificates issued by securitization trusts and sought to apply the benefits of the 2008 treaty, for …