https://www.taxtmi.com/caselaws?id=406869 Treaty relief under Article 11 of the India-Cyprus DTAA depended on whether the assessee was the beneficial owner of the interest income. The adverse view was based mainly on a nil disclosure in the return and a conduit allegation, but the financial statements and supporting records showing subsidiaries, CCD holdings, borrowings and related balance-sheet details were not examined. Because the factual foundation was incomplete and the beneficial ownership test had not been properly applied, the adverse finding was set aside and the matter restored for fresh adjudication. en-us Tue, 02 Mar 2021 00:00:00 +0530 Mon, 26 Apr 2021 10:19:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406869 Treaty relief under Article 11 of the India-Cyprus DTAA depended on whether the assessee was the beneficial owner of the interest income. The adverse view was based mainly on a nil disclosure in the return and a conduit allegation, but the financial statements and supporting records showing subsidiaries, CCD holdings, borrowings and related balance-sheet details were not examined. Because the factual foundation was incomplete and the beneficial ownership test had not been properly applied, the adverse finding was set aside and the matter restored for fresh adjudication. Case-Laws Income Tax Tue, 02 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406869