Tax alert: Taxpayer eligible for tax treaty benefit basis TRC and other facts

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.

Did you find this useful?