Income from investment in Trust by ADIA is exempt in terms of India-UAE DTAA

Abu Dhabi Investment Authority Vs Authority for Advance Ruling (Bombay High Court) Facts- ADIA files ROI in India disclosing income falling within the scope of section 5(2). However, in view of exemption available in terms of India-UAE DTAA, ADIA reports NIL taxable income. AAR denies the benefit of India-UAE DTAA benefit to ADIA in respect of income accruing on the investment made or proposed to be made by Green Maiden A 2013 Trust which was established by ADIA and ETL. Conclusion- ADIA is the sole beneficiary of the trust, the income assessed in the hands of the trustee will take colour of ...