Capital gain earned on sale of share not taxable in India in terms of India-Singapore DTAA

Blackstone Capital Partners (Singapore) Vi Fdi Three Pte. Ltd. Vs ACIT (Delhi High Court) Delhi High Court held that capital gain earned on sale of shares by non-resident is not taxable in terms of Article 13(4) of India and Singapore (DTAA) based on Tax Residency Certificate. Also held that revenue has to accept Tax Residency Certificate and cannot go behind it. Facts- The core issue that came up for consideration in the present writ petition filed by the aggrieved petitioner-assessee was whether the respondent-revenue can go behind the tax residency certificate issued by the other tax jurisd...