https://www.taxtmi.com/caselaws?id=233377 The Tribunal upheld the assessee's entitlement to the benefits of Article 12 of the DTAA between India and Netherlands, as the evidence, including a certificate from revenue authorities in Netherlands, established the assessee as the beneficial owner of the royalty income. The respondent failed to challenge these factual findings, leading to the dismissal of the appeal without costs. The judgment emphasized the significance of factual evidence in determining beneficial ownership for tax purposes under international agreements like the DTAA. en-us Fri, 08 Feb 2013 00:00:00 +0530 Mon, 29 Apr 2013 08:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233377 The Tribunal upheld the assessee's entitlement to the benefits of Article 12 of the DTAA between India and Netherlands, as the evidence, including a certificate from revenue authorities in Netherlands, established the assessee as the beneficial owner of the royalty income. The respondent failed to challenge these factual findings, leading to the dismissal of the appeal without costs. The judgment emphasized the significance of factual evidence in determining beneficial ownership for tax purposes under international agreements like the DTAA. Case-Laws Income Tax Fri, 08 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233377