SANJAY KISHAN KAUL, J. (Oral)

1. The present petition under Article 226 of the Constitution styled as a Public Interest Litigation has been filed seeking multifarious reliefs including of declaration arising from the grievance of the petitioner about the mode and manner in which the governance of international treaties are sought to be made applicable to the citizens of India. It is the case of the petitioner, who appears in person, that the powers and authority of the Central Government are being abused and are sought to be exercised in violation of the constitutional mandate by entering into Double Taxation Avoidance Agreements (more specifically in relation to the provisions relating to Mutual Agreement Procedure), ratification and adoption of Uruguay Round Final Act (WTO Treaty) and the provisions relating to the MAP set forth in the CBDT’s Instruction as also under the Income Tax Rules 1962.

2. The petitioner took us through the pleadings and the various synopsis fileby him to firstly contend that in matters of taxation the mode adopted by the Central Government was impermissible. The petitioner is, however, conscious of the observations made by the Supreme Court in