AO rejected assessee’s claim holding that assessee failed to prove that exemption for dividend income was provided as an incentive for economic development. CIT (A) held at India-Cyprus DTAA did not cast burden of proving that tax exemption was in respect of economic development on claimant let alone establishing that tax exemption was in relation to ‘special’ economic development and also held that by giving exemption/tax incentive in respect of dividend income, Cyprus was definitely contributing to promotion of its economic development and, thus, no other specific evidence was mandated by law to establish that exemption in question was designed to promote economic development. Accordingly allowed the claim of the assessee. Order of CIT (A) is affirmed by the Tribunal. (AY. 2008-09)