Relevance of Tax Residency Certificate, while claiming the benefit of the double taxation avoidance agreement
The Hon’ble Delhi ITAT in its recent decision in the case of Sarva Capital LLC, has yet another time re-emphasised that the relevance of Tax Residency Certificate, while claiming the benefit of the double taxation avoidance agreement.
This decision is all the more important since it appears to be the first decision pronounced after the judgement of Hon’ble Delhi High Court in the case of BLACKSTONE CAPITAL PARTNERS (SINGAPORE) VI FDI THREE PTE. LTD. was stayed by the Hon’ble Supreme Court on 12 January 2024.
It is a welcome decision, reinstating the reliance on Tax Residency Certificate.
The copy of the order is as under:
