Will Tax Residency Certificate [TRC] be sufficient ? May not be?

Skaps Industries India Pvt Ltd Vs ITO (ITAT Ahmedabad) Author in this articles discusses recent decision of ITAT – Ahmedabad holding that: 1. an eligible assessee cannot be declined the Treaty protection under section 90(2) of the Income Tax Act, 1961 [the Act] on the ground that the said assessee has not been able to furnish a Tax Residency Certificate [TRC] in the prescribed form as required by the section 90(4). 2. but production of TRC by itself may not be sufficient… The second limb of law as laid down may put an onerous obligation of payers in India. Citation of the case Skaps Indust...