https://www.taxtmi.com/caselaws?id=433520 The court held that the respondent-revenue cannot question the Tax Residency Certificate (TRC) issued by another tax jurisdiction, emphasizing its conclusive nature for claiming treaty benefits. The re-assessment notice under Section 147 was deemed invalid due to borrowed satisfaction and lack of independent assessment. Reasons for believing income had escaped assessment were found to lack reasonable grounds. The TRC sufficiency for treaty benefits under the India-Singapore DTAA was upheld, along with compliance with the Limitation of Benefit clause. The order disposing of objections to the re-assessment notice was considered arbitrary. Ultimately, the court ruled that no taxable income had escaped assessment, quashing the re-assessment proceedings. en-us Mon, 30 Jan 2023 00:00:00 +0530 Thu, 28 May 2026 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433520 The court held that the respondent-revenue cannot question the Tax Residency Certificate (TRC) issued by another tax jurisdiction, emphasizing its conclusive nature for claiming treaty benefits. The re-assessment notice under Section 147 was deemed invalid due to borrowed satisfaction and lack of independent assessment. Reasons for believing income had escaped assessment were found to lack reasonable grounds. The TRC sufficiency for treaty benefits under the India-Singapore DTAA was upheld, along with compliance with the Limitation of Benefit clause. The order disposing of objections to the re-assessment notice was considered arbitrary. Ultimately, the court ruled that no taxable income had escaped assessment, quashing the re-assessment proceedings. Case-Laws Income Tax Mon, 30 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433520