Department Must Substantiate Shell Company Claim Despite: ITAT Delhi

CPI India Ltd. Vs ACIT (ITAT Delhi)

Conclusion: Even though the department had the authority to dispute the residential status of the assessee merely on the strength of the Tax Residency Certificate (TRC), it was incumbent upon the department to make a proper inquiry and to establish the fact that the party claiming benefit and the strength of the TRC was a shell or conduit company.

Held: Assessee was an investment holding company incorporated under the Ma

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