https://www.taxtmi.com/caselaws?id=449242 A valid Tax Residency Certificate issued by Mauritius was treated as sufficient evidence of residence for India-Mauritius DTAA purposes, and Indian tax authorities could not disregard it to deny treaty benefits on grounds of treaty shopping, conduit arrangement, lack of commercial rationale, or alleged absence of tax liability in Mauritius. The phrase "liable to taxation" was read as distinct from actual tax payment, so exemption under Mauritian domestic law did not by itself defeat treaty eligibility. On capital gains, shares acquired before 01.04.2017 were protected by the Article 13(4) grandfathering rule, and CCPS converted into equity after that date were treated as pre-cut-off acquisitions for treaty protection. en-us Mon, 05 Feb 2024 00:00:00 +0530 Thu, 08 Feb 2024 08:12:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449242 A valid Tax Residency Certificate issued by Mauritius was treated as sufficient evidence of residence for India-Mauritius DTAA purposes, and Indian tax authorities could not disregard it to deny treaty benefits on grounds of treaty shopping, conduit arrangement, lack of commercial rationale, or alleged absence of tax liability in Mauritius. The phrase "liable to taxation" was read as distinct from actual tax payment, so exemption under Mauritian domestic law did not by itself defeat treaty eligibility. On capital gains, shares acquired before 01.04.2017 were protected by the Article 13(4) grandfathering rule, and CCPS converted into equity after that date were treated as pre-cut-off acquisitions for treaty protection. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449242