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Tax Residency Certificate Challenges in India: Implications for India-Mauritius DTAA and Foreign Investment Policy u/s 263.
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....Revision u/s 263 - Income taxable in India - evidence of residence - TRC produced by a resident of a contracting state - benefits under India- Mauritius DTAA - the Revenue’s attempt to question and to behind the TRC is wholly contrary to the Government of India’s consistent policy and repeated assurances to Foreign Investors. - AT....