https://www.taxtmi.com/caselaws?id=6130 The SC upheld the validity of CBDT Circular No. 789 regarding the Indo-Mauritius Double Taxation Avoidance Convention (DTAC), 1983. The court held that entities incorporated under Mauritius laws are liable to taxation and qualify as residents under the DTAC, even if granted exemptions on specific income sources. The circular was deemed within CBDT's powers under section 119 and did not curtail Assessing Officers' jurisdiction. The court rejected the principle of piercing the corporate veil in treaty interpretation contexts and recognized treaty shopping as potentially necessary in developing economies. The HC judgment quashing the circular was set aside. en-us Tue, 07 Oct 2003 00:00:00 +0530 Wed, 02 Jul 2025 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6130 The SC upheld the validity of CBDT Circular No. 789 regarding the Indo-Mauritius Double Taxation Avoidance Convention (DTAC), 1983. The court held that entities incorporated under Mauritius laws are liable to taxation and qualify as residents under the DTAC, even if granted exemptions on specific income sources. The circular was deemed within CBDT's powers under section 119 and did not curtail Assessing Officers' jurisdiction. The court rejected the principle of piercing the corporate veil in treaty interpretation contexts and recognized treaty shopping as potentially necessary in developing economies. The HC judgment quashing the circular was set aside. Case-Laws Income Tax Tue, 07 Oct 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6130