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Analysis of AAR Ruling in the case of Tiger Global

June 30, 2020[2020] 117 404 (Article)
Article 13(4) of the India-Mauritius tax treaty provides that gains from alienation of any property other than immovable property (para 1), movable property forming part of business property of permanent establishment (para 2), ships and aircrafts (para 3), shares acquired on or after 1 April 2017 in company that is resident of a contracting state (para 3A); shall be taxable only in the contracting state of which alienator is resident.
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