Read the detailed analysis of Sarva Capital LLC Vs ACIT (ITAT Delhi) regarding the validity of Tax Residency Certificate (TRC) for determining treaty benefits under the India-Mauritius Double Taxation Avoidance Agreement (DTAA).
ITAT Delhi held that as shares were acquired prior to 01.04.2017, gain derived from sale of such equity shares is exempt under Article 13(4) of India-Mauritius DTAA.