Court Rules Tax Residency Certificate Sufficient for Treaty Eligibility; No Capital Gains Tax in India for Foreign Shares Sale.

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....Reopening of assessment u/s 147 - Unexplained gain on sale of shares of company abroad - the respondent-revenue cannot go behind the TRC issued by the other tax jurisdiction as the same is sufficient evidence to claim treaty eligibility, residence status, legal ownership and accordingly there is no capital gain earned by the petitioner liable to tax in India - HC....