https://www.taxtmi.com/caselaws?id=289051 A Mauritius tax resident relying on its Tax Residency Certificate and CBDT Circular No. 789 claimed treaty relief on interest income under Article 11(3)(c) of the India-Mauritius DTAA. The Tribunal reasoned that the circular is not limited to dividend or capital gains income and can also apply to interest income, and that judicial precedent supported this reading. As the Revenue produced no material to rebut the position arising from the residency certificate, the assessee was treated as the beneficial owner of the interest income and the income was held not taxable in India under the treaty. en-us Mon, 02 Jul 2018 00:00:00 +0530 Sat, 11 Jul 2020 10:35:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289051 A Mauritius tax resident relying on its Tax Residency Certificate and CBDT Circular No. 789 claimed treaty relief on interest income under Article 11(3)(c) of the India-Mauritius DTAA. The Tribunal reasoned that the circular is not limited to dividend or capital gains income and can also apply to interest income, and that judicial precedent supported this reading. As the Revenue produced no material to rebut the position arising from the residency certificate, the assessee was treated as the beneficial owner of the interest income and the income was held not taxable in India under the treaty. Case-Laws Income Tax Mon, 02 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289051