Assessee, a non-resident, based in New Jersey, was a revocable and determinant trust settled by Abu Dhabi Investment Authority (ADIA) through deed of settlement with Equity Trust Jersey Ltd. (ETJL) acting as trustee of trust. It filed nil return. Trustee of assessee-trust (ETJL) and ADIA had filed an application before AAR claiming tax exemption on interest earned from investment made in non-convertible debenture of Indian portfolio companies as per article 24 of India-UAE DTAA. AAR held that said interest income was taxable in India as income from investment in debt portfolio in India had been received or accrued to assessee-trust in India and was taxable under section 5 read with section 9(1)(i). Assessing Officer in accordance with ruling of AAR taxed interest income as per section 115AD. On appeal the Tribunal held that assessee had filed a writ petitions before High Court challenging ruling pronounced by AAR wherein High Court had held that income earned by assessee-trust was not chargeable to tax in India either by virtue of application of section 61 read with section 63 or an application of section 161, conjointly with provision of article 24 of India-UAE DTAA. Since addition to taxable income had proposed by Assessing Officer on basis of AAR ruling which had already been reversed by High Court, same is  be set aside. (AY. 2016-17  to 2018-19)