On writ allowing the petition the Court held that certificate of residence issued by Mauritius Authorities would constitute sufficient evidence. Authority for Advance Rulings denying to benefits of Double Taxation Avoidance Agreement on ground that the assessee shell company and was treaty shopping held to be not valid. Matter Remanded to Authority for Advance Rulings for reconsideration. Referred CBDT Circular No Central Board Of Direct Taxes Circular Nos. 682, Dated 30-3-1994 ([1994] 207 ITR (St.) 7) and 789 Dated 13-4-2000 ([2000] 243 ITR (St.) 57), UOI v. Azadi Bachao Andolan (2003) 263 ITR 706 (SC) Vodafone International Holdings B.V. v. UOI ( 20012 ) 341 ITR 1 (SC). Court also observed that although scrutiny in writ jurisdiction under article 226 of the Constitution of India of orders passed by the Authority for Advance Rulings is minimal they can be interfered with if the ruling is without considering the entire material on record or the submissions made on behalf of the parties or the ruling suffers from a fundamental error or is absurd or perverse. Accordingly the matter was remanded back to the Authority for reconsideration after giving opportunity of hearing to the assessee and the Department. Accordingly, the ruling passed by the Authority for Advance Ruling was quashed and set aside.