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    <title>1997 (7) TMI 669 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>For treaty purposes, a company incorporated in Mauritius was treated as resident in Mauritius where its effective management, board meetings, records, banking and compliance were centred there, and foreign investor links did not defeat treaty entitlement. Interest from approved debt transactions was exempt in India only where the underlying transaction had specific governmental approval and only to the extent allowed by Indian tax law. Capital gains on transfer of shares in Indian companies were not taxable in India once Mauritius residence was accepted. Residual income, including income from mutual fund units not covered by specific treaty articles, fell under the residuary treaty rule and was taxable only in Mauritius, not in India.</description>
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      <description>For treaty purposes, a company incorporated in Mauritius was treated as resident in Mauritius where its effective management, board meetings, records, banking and compliance were centred there, and foreign investor links did not defeat treaty entitlement. Interest from approved debt transactions was exempt in India only where the underlying transaction had specific governmental approval and only to the extent allowed by Indian tax law. Capital gains on transfer of shares in Indian companies were not taxable in India once Mauritius residence was accepted. Residual income, including income from mutual fund units not covered by specific treaty articles, fell under the residuary treaty rule and was taxable only in Mauritius, not in India.</description>
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