Author: Ameet Baid, Chandandeep Kaur & Ishmeet Kaur, ASA
In this article, a Mumbai ITAT ruling is examined to show how commercial substance and genuine intent can outweigh formal presence when claiming treaty benefits. It explains how grandfathered investments, economic substance, and effective control helped sustain capital gains exemption under the India–Singapore DTAA despite Principal Purpose Test scrutiny.
Published on – Taxmann
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