Held that the assessee is  a resident of Mauritius and there is  a tax residency certificate issued in favour of the assessee by Mauritius. Circulars of the Board and judgments of the Supreme Court sufficiently lay down that the tax residency certificates are statutory evidence of the residential status and even if it is not conclusive evidence, the onus shifts to the Assessing Officer to establish by evidence that except for holding the tax residency certificate, the entity is a conduit, created and run for treaty shopping.  The directors were professionals with qualifications and experience commensurate with the responsibility of managing the funds. All decisions with respect to the affairs of the assessee were taken by the board in Mauritius. All share purchase agreements for the transfer of shares were executed by the Mauritian resident directors.  The authorities  had failed to rebut the statutory evidence of the tax residency certificate with cogent evidence, and merely on the basis of suspicion and inferences, the assessee had been held to be engaged in treaty-shopping. The mere fact that the assessee was a drop down entity associated with entities operating in the Cayman Islands did not taint the genuine activities of the assessee as an investment platform. The doctrine of ”substance over form” cannot be stretched to the extent that merely because the assessee had associated enterprises operating from the Cayman Islands, the investments made in a prestigious Indian company in the initial years of its growth would also become tainted. The minuscule percentage of the funds of the assessee invested in India rebutted all the inferences drawn by the authorities    same can not be sustained.  The findings of the Assessing Officer as affirmed by the Dispute Resolution Panel is  reversed, and the claim for exemption was allowed.(AY. 2020-21)