Tax Residency Certificate is only evidence required to be eligible for benefit under DTAA

Sapein Funds Ltd. Vs CIT (ITAT Delhi) ITAT Delhi held that Tax Residency Certificate (TRC) is statutorily the only evidence required to be eligible for the benefit under the DTAA. Accordingly, benefit of India-Mauritius DTAA duly available. Facts- Sapien Funds Limited (SFL) is incorporated and registered outside India according to the law of Mauritius with a permanent establishment in Mauritius and a Tax Residency in Mauritius, the Tax Residence Certificate in this regard has been provided to IT authorities in India. SFL is an independent and distinct corporate legal entity. SFL is managed by ...