1. Introduction: Challenges of Taxing the Digital Economy

THE rapid proliferation of digital technologies has revolutionized the global economic and tax environment, and India is positioned at the epicenter of this digital transformation. As multinational enterprises deploy cloud computing, Software-as-a-Service (SaaS), and data-driven infrastructures to provide on-demand, cross-border digital services, the resulting complexity has

THE current India USA text treaty was finalised in the year 1989 and came into effect in the year 1990. This was the time when India's economy was going through difficult times and foreign exchange crisis made the Indian economy even more vulnerable. At that time, India was in