RE: Update5 Feb 2019 12:01
Same point, you're still wrong to intimate both that India have accepted that the arbitration Tribunal can correctly rule on tax, and that India has agreed to comply with the forthcoming ruling whatever's in it. India believes its domestic tax law trumps the treaty. Acceptance or not by India of the ruling, process and enforceability, remain as issues, as reflected in very little value attributed in the SP to the claim. Hopefully we'll get a chunky award, and India will pay up promptly, so as not to discourage foreign trade and investment going forward, but we'll have to wait and see.
All just imo of course.