2024 (1) TMI 278

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... it on sale of Agile shares were not taxable in India by virtue of Article 13(4) the Double Tax Avoidance Agreement entered into and subsisting between India and Singapore ( India-Singapore DTAA ) based on the Tax Residency Certificate ( TRC ) - Relevance of information from a third party - borrowed satisfaction - Beneficial ownership under DTAA - Companies to be incorporated initially with min .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... notice on the application seeking condonation of delay as well as on the Special Leave Petition. In the meantime, operation of the impugned order shall remain stayed. - HON'BLE MR. JUSTICE PAMIDIGHANTAM SRI NARASIMHA And HON'BLE MR. JUSTICE ARAVIND KUMAR For the Petitioner : Mr. N Venkatraman, A.S.G. Mr. Raj Bahadur Yadav, AOR Mrs. Nisha Bagchi, Adv. Mr. H R Rao, Adv. Mr. Akshi .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X