https://www.taxtmi.com/caselaws?id=438993 The Tribunal concluded that the order issued by the Principal Commissioner of Income Tax (PCIT) under Section 263 was beyond jurisdiction and therefore invalid. The original assessment under Section 143(3) was upheld as correct and lawful, with the Tribunal finding no error in the Assessing Officer's decision. The Tribunal affirmed that the assessee, a tax resident of Mauritius, was entitled to benefits under the India-Mauritius DTAA, with the Tax Residency Certificate (TRC) deemed sufficient evidence of residency. Allegations of treaty shopping were dismissed, and the appeal of the assessee was allowed, rendering the income non-taxable in India. en-us Thu, 08 Jun 2023 00:00:00 +0530 Mon, 16 Mar 2026 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438993 The Tribunal concluded that the order issued by the Principal Commissioner of Income Tax (PCIT) under Section 263 was beyond jurisdiction and therefore invalid. The original assessment under Section 143(3) was upheld as correct and lawful, with the Tribunal finding no error in the Assessing Officer's decision. The Tribunal affirmed that the assessee, a tax resident of Mauritius, was entitled to benefits under the India-Mauritius DTAA, with the Tax Residency Certificate (TRC) deemed sufficient evidence of residency. Allegations of treaty shopping were dismissed, and the appeal of the assessee was allowed, rendering the income non-taxable in India. Case-Laws Income Tax Thu, 08 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438993