Tax alert: Taxpayer eligible for tax treaty benefit basis TRC and other facts has been saved
Article
Tax alert: Taxpayer eligible for tax treaty benefit basis TRC and other facts
29 January 2025
The Delhi Bench of the Income-tax Appellate Tribunal, based on facts, has held that the benefit under India-Luxembourg tax treaty cannot be denied to the taxpayer when the taxpayer submitted the tax residency certificate (TRC), proved its existence from the date of its investment in the source country and the Revenue also could not bring on record any cogent material to establish that the taxpayer in substance was only a conduit company.