Held that Tax residency certificate, even though it is not a conclusive evidence of tax residency of an entity, it certainly is a statutory evidence and the burden is on the Revenue to establish from the facts and circumstance that the entity has been formed and operated in a manner that the only intention was to take benefit of the tax treaty without there being actual intention of an economic activity. There is no finding of the AO or the DRP as to whether any inquiry was independently conducted to rebut the statutory evidence of tax residency. Thus, at first instance the initial burden was discharged by the assessee by filing the statutory evidence of tax residency in the form of TRC, and the same was not rebutted by any inquiry or evidence by the AO. (AY. 2017-18)