https://www.taxtmi.com/caselaws?id=396607 A Mauritius resident bank's interest income was treated as exempt in India under Article 11(3)(c) of the India-Mauritius tax treaty because the assessee held a valid Tax Residency Certificate, a banking licence, and was found to be the beneficial owner of the income. The Tribunal followed earlier coordinate bench rulings in the assessee's own case, and treated CBDT Circular No. 789 as supporting the treaty claim. It accepted the Mauritian authority's certificate as sufficient evidence of residence and beneficial ownership, and rejected the Revenue's conduit company argument for want of contrary material evidence. The first appellate relief was sustained, and the interest income was held not taxable in India. en-us Wed, 08 Jul 2020 00:00:00 +0530 Fri, 08 Nov 2024 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396607 A Mauritius resident bank's interest income was treated as exempt in India under Article 11(3)(c) of the India-Mauritius tax treaty because the assessee held a valid Tax Residency Certificate, a banking licence, and was found to be the beneficial owner of the income. The Tribunal followed earlier coordinate bench rulings in the assessee's own case, and treated CBDT Circular No. 789 as supporting the treaty claim. It accepted the Mauritian authority's certificate as sufficient evidence of residence and beneficial ownership, and rejected the Revenue's conduit company argument for want of contrary material evidence. The first appellate relief was sustained, and the interest income was held not taxable in India. Case-Laws Income Tax Wed, 08 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396607