https://www.taxtmi.com/caselaws?id=289056 Beneficial ownership of interest income under the India-Mauritius tax treaty was upheld where the assessee held a Mauritian Certificate of Residence and had already been found in its own case to be the beneficial owner. The ITAT Mumbai applied CBDT Circular No. 789 and treated the residence certificate as sufficient evidence of residence and beneficial ownership for treaty purposes, extending that approach to interest income under Article 11(3)(c) even though the circular was framed in relation to dividend and capital gains. On that basis, the assessee was entitled to treaty exemption and the Revenue's challenge failed. en-us Fri, 20 Mar 2020 00:00:00 +0530 Sat, 11 Jul 2020 10:35:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289056 Beneficial ownership of interest income under the India-Mauritius tax treaty was upheld where the assessee held a Mauritian Certificate of Residence and had already been found in its own case to be the beneficial owner. The ITAT Mumbai applied CBDT Circular No. 789 and treated the residence certificate as sufficient evidence of residence and beneficial ownership for treaty purposes, extending that approach to interest income under Article 11(3)(c) even though the circular was framed in relation to dividend and capital gains. On that basis, the assessee was entitled to treaty exemption and the Revenue's challenge failed. Case-Laws Income Tax Fri, 20 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289056