https://www.taxtmi.com/article/detailed?id=12990 The Delhi High Court held that the Assessee possessed genuine economic substance in Mauritius, that a Tax Residency Certificate should be treated as conclusive proof of residence absent compelling evidence of fraud or sham, and that the DTAA grandfathering provision applied so Limitation of Benefits did not preclude treaty relief for qualifying share acquisitions; domestic anti avoidance rules should not displace treaty entitlement where treaty anti abuse measures and evidence of substance are satisfied. en-us Fri, 04 Oct 2024 15:31:43 +0530 Fri, 04 Oct 2024 15:31:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=12990 The Delhi High Court held that the Assessee possessed genuine economic substance in Mauritius, that a Tax Residency Certificate should be treated as conclusive proof of residence absent compelling evidence of fraud or sham, and that the DTAA grandfathering provision applied so Limitation of Benefits did not preclude treaty relief for qualifying share acquisitions; domestic anti avoidance rules should not displace treaty entitlement where treaty anti abuse measures and evidence of substance are satisfied. Articles Income Tax Fri, 04 Oct 2024 15:31:43 +0530 https://www.taxtmi.com/article/detailed?id=12990