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ITAT adjudicated a cross-border taxation dispute involving long-term capital gains (LTCG) from share sale under India-Cyprus Double Taxation Avoidance Agreement (DTAA). The tribunal conclusively determined that the assessee, incorporated in Cyprus, was genuinely managed from Cyprus and not a pass-through entity. Despite Revenue's allegations of treaty abuse, the tribunal found the assessee's submissions meritorious, affirming its entitlement to DTAA benefits. The tribunal rejected Revenue's contentions that the real beneficiaries were US-based, emphasizing the assessee's substantive presence and tax residency certificate in Cyprus. Consequently, the ground challenging DTAA applicability was allowed in favor of the assessee.
ITAT adjudicated a cross-border taxation dispute involving long-term capital gains (LTCG) from share sale under India-Cyprus Double Taxation Avoidance Agreement (DTAA). The tribunal conclusively determined that the assessee, incorporated in Cyprus, was genuinely managed from Cyprus and not a pass-through entity. Despite Revenue's allegations of treaty abuse, the tribunal found the assessee's submissions meritorious, affirming its entitlement to DTAA benefits. The tribunal rejected Revenue's contentions that the real beneficiaries were US-based, emphasizing the assessee's substantive presence and tax residency certificate in Cyprus. Consequently, the ground challenging DTAA applicability was allowed in favor of the assessee.
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