India–Singapore DTAA Benefit Denied; Capital Gains Taxed as Entity Held Shell/Conduit

Hareon Solar Singapore Pvt. Ltd. Vs DCIT (ITAT Delhi) India–Singapore DTAA Benefit Denied; Capital Gains Taxed in India as Singapore Entity Held Shell/Conduit The Delhi Bench of the ITAT dismissed the appeal of Hareon Solar Singapore Pvt. Ltd. for AY 2020-21 and upheld the taxation of capital gains in India arising from the sale of equity shares and CCDs of an Indian company, Renew Solar Energy (Karnataka) Pvt. Ltd. The Tribunal held that although the assessee possessed a Tax Residency Certificate (TRC) of Singapore, mere production of TRC was not conclusive to claim treaty benefits under th...