Residence certification under Indo-Mauritius DTAC secures treaty relief for dividends and capital gains, limiting Indian taxation. Certificates of residence issued by Mauritian authorities constitute sufficient evidence of residence and beneficial ownership for applying the Indo-Mauritius DTAC; entities taxable in Mauritius qualify as residents and may claim treaty relief for dividends, and residents of Mauritius should not be taxable in India on capital gains from sale of shares under the Convention; the clarification applies to pending proceedings.