https://www.taxtmi.com/caselaws?id=289051 The Tribunal ruled in favor of the assessee, holding that the interest income of Rs. 94,57,45,856 was not taxable in India as the assessee met the criteria of beneficial ownership under Article 11(3)(c) of the India-Mauritius Tax Treaty. The Tribunal emphasized the validity of the Tax Residency Certificate from Mauritian authorities and legal interpretations, concluding that the assessee was the beneficial owner of the income. The appeal was allowed, affirming the non-taxability of the interest income in India based on the provisions of the tax 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 The Tribunal ruled in favor of the assessee, holding that the interest income of Rs. 94,57,45,856 was not taxable in India as the assessee met the criteria of beneficial ownership under Article 11(3)(c) of the India-Mauritius Tax Treaty. The Tribunal emphasized the validity of the Tax Residency Certificate from Mauritian authorities and legal interpretations, concluding that the assessee was the beneficial owner of the income. The appeal was allowed, affirming the non-taxability of the interest income in India based on the provisions of the tax treaty. Case-Laws Income Tax Mon, 02 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289051