Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
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