Assessee had not filed a return of income for the assessmet year 2016-17  on the ground that  it had been issued a TRC under laws of Mauritius, it was entitled to take benefit of provisions of article 13 of DTAA between India and Mauritius. Reassessment notice was issued to the assesee. The assessee filed writ petition cahllnging the issue of notice under section. 148 of the Act. the   Revenue contended  that Tax Residency Certificate (TRC) issued was not a conclusive evidence on assessee’s residential status, thus, held assessee ineligible for treaty benefits. Court hedl that  nothing in form of information or material had been put on record by revenue to conclude that Tax Residency Certificate (TRC) issued to assessee was not a viable legal document. Accordingly  reassessment proceedings initiated against assessee is set aside and matter was to be remanded back to AO to confront assessee with relevant material. (AY. 2016-17)