Article 13 of India-Mauritius DTAA; section 245R of the Act – As gain on sale of shares by a Mauritius company in a Singapore company which derived substantial value from assets in India was, prima facie, designed for avoidance of tax, applications were to be rejected under clause (iii) to proviso to section 245R(2) of the Act
Dhishat B. Mehta | Bhaumik Goda Chartered Accountants