Tribunal held that when the assessee has provided all other details the Assessing Officer should have verified the PAN and the address provided in the return to see whether the assessee is an Abu Dhabi Government owned company i.e., Abu Dhabi Investment Authority. The assessee had shown its valid registration as category of foreign portfolio investor obtained with SEBI and holds a valid residency certificate and given the particulars of income, there is no reason to doubt that it is not the authority as mentioned in art. 24. Accordingly, the assessee is entitled to benefit and denial of exemption is not valid. (AY.2019-20)
Abu Dhabi Investment Authority v. DCIT (IT) (2024) 160 taxmann.com 104 /228 TTJ 721 /236 DTR 1 / 38 NYPTTJ 227 (Mum)(Trib)
S. 90 : Double taxation relief-Valid registration certificate-Denial of exemption is not justified-DTAA-India-UAE [Art. 24(2)(b)((ii)]
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