India-Mauritius DTAA: Assessing Beneficial Ownership of Interest Income for Exemption under Article 11(3)(c.

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....Income accrued in India - Interest income from foreign currency loan and Securities - proof of beneficial ownership of funds - eligibility ot claim exemption under Article 11(3)(c) of India-Mauritius DTAA - assessee is the 'beneficial owner' of the impugned interest income on the strength of the Tax Residency Certificate issued by the Mauritian authorities - AT....