Indian Tax Tribunal Holds Residence Certificate is Sufficient Proof of Beneficial Ownership under Tax Treaty with Mauritius

The Mumbai Income Tax Appellate Tribunal recently issued a decision concerning whether a certificate of residence issued by the Mauritius authority is sufficient proof of beneficial ownership. The case involved HSBC Bank (Mauritius) Ltd. (HSBC), which derived interest income from investments in Indian debt securities.
Based on paragraph 3(c) of Article 11 (Interest) of the 1982 India-Mauritius…
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