https://www.taxtmi.com/highlights?id=80149 The Appellant, a Mauritian entity, is controlled and managed by its board of directors in Mauritius, comprising two Mauritian resident directors and one US resident director. Board meetings were physically chaired in Mauritius, with the majority of directors being Mauritian residents. The tax authorities failed to rebut the statutory evidence of the Tax Residency Certificate with cogent evidence and merely based on suspicion and inferences, held the assessee engaged in treaty shopping. The assessee had no funds of its own due to its nature as an investment platform, and any gains would be transferred to initial investors. The assessee's association with Cayman Island entities does not taint its genuine activities as an investment platform. ..... en-us Tue, 06 Aug 2024 07:50:23 +0530 Tue, 06 Aug 2024 07:50:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=80149 The Appellant, a Mauritian entity, is controlled and managed by its board of directors in Mauritius, comprising two Mauritian resident directors and one US resident director. Board meetings were physically chaired in Mauritius, with the majority of directors being Mauritian residents. The tax authorities failed to rebut the statutory evidence of the Tax Residency Certificate with cogent evidence and merely based on suspicion and inferences, held the assessee engaged in treaty shopping. The assessee had no funds of its own due to its nature as an investment platform, and any gains would be transferred to initial investors. The assessee's association with Cayman Island entities does not taint its genuine activities as an investment platform. ..... Highlights Income Tax Tue, 06 Aug 2024 07:50:23 +0530 https://www.taxtmi.com/highlights?id=80149