Departmental authorities cannot question validity of Tax Residency Certificate

Saif II-SE Investments Mauritius Limited Vs ACIT (ITAT Delhi) ITAT Delhi held that that the departmental authorities cannot question the validity of Tax Residency Certificate. Once the assessee holds a valid TRC, it proves the residential status of the assessee as resident of Mauritius, hence, it will be eligible to treaty benefits. Facts- The assessee is a non-resident corporate entity incorporated in Mauritius and is a tax resident of Mauritius. As stated by AO, the assessee operates as an investment holding company, undertaking various investments. AO noted that the assessee holds a valid ...