https://www.taxtmi.com/caselaws?id=439167 A Tax Residency Certificate supporting treaty protection under the India-Mauritius DTAA could not be rejected on tentative allegations of treaty shopping without first supplying the assessee with the material relied upon. Where the adverse inference was drawn without confronting the petitioner with relevant information, the jurisdictional order could not be sustained. The proper course was to set aside the impugned order and require the Assessing Officer to disclose the material, if any, before taking further action; the connected notices issued thereafter could not survive. en-us Tue, 30 May 2023 00:00:00 +0530 Sat, 20 Sep 2025 13:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439167 A Tax Residency Certificate supporting treaty protection under the India-Mauritius DTAA could not be rejected on tentative allegations of treaty shopping without first supplying the assessee with the material relied upon. Where the adverse inference was drawn without confronting the petitioner with relevant information, the jurisdictional order could not be sustained. The proper course was to set aside the impugned order and require the Assessing Officer to disclose the material, if any, before taking further action; the connected notices issued thereafter could not survive. Case-Laws Income Tax Tue, 30 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439167