The Mumbai Bench of the India Authority for Advance Rulings (AAR) on 10 February 2020 issued a decision denying tax treaty benefits to a Mauritius company on the grounds that the company lacked economic substance and was interposed in a holding chain merely to obtain benefits under the 1982 India-Mauritius tax treaty.
The Mauritius company (Mco) is a subsidiary of a South African company and, following an international bid for tenders, entered into a joint venture (MIAL) with two other India…