Assessee, a Foreign Institutional Investor (FII) and tax resident of Mauritius had e-filed its return of income declaring its total income at Rs. Nil.  The AO held that the assessee had failed to substantiate material aspect that it was beneficial owner of interest income and not a conduit company.  The Assessee  submitted that interest income of Rs. 273 crores on foreign currency loans and Rs. 1225 crores on debt securities was exempt under article 11(3)(c).  Tribunal held that beneficial provisions envisaged in article 11(3)(c) would be applicable to interest income received by assessee rendering said receipts as not exigible to tax in India. Followed the order for earlier year. (AY. 2015-16)