India's Authority of Advance Ruling (AAR) recently issued a ruling on whether the capital gains tax relief provided under the 1982 India-Mauritius tax treaty may apply on the transfer of an Indian company's shares by a Mauritius company to a U.S. company. The ruling involves Mahindra BT Investment Company (Mauritius) Limited (Mauritius Co) and the transfer of shares in India-based Tech Mahindra Limited (India Co) to U.S.-based AT&T International Inc.
In the year concerned, Mauritius Co t…