Denial of Treaty Benefits in India-Mauritius DTAA Case: Tax Residency Certificate Acceptance vs. Conduit Company Allegations.

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....Denial of treaty benefits treating the assessee as a conduit company set up - Taxability of long-term capital gain claimed as exempt under Article 13(4) of India – Mauritius DTAA - Though, AO has alleged that the assessee is a conduit company and has been set up as a part of tax avoidance arrangement, surprisingly, he has not invoked the provisions of GAAR as provided under Chapter XA of the Act. - TRC issued by the competent authority in Mauritius has to be accepted - AT....