FULL JUDGMENT – http://supremecourtofindia.nic.in/outtoday/sc2652910.pdf
Our Analysis
58. Before coming to Indo-Mauritius DTAA, we need to clear
31
the doubts raised on behalf of the Revenue regarding the
correctness of Azadi Bachao (supra) for the simple reason that
certain tests laid down in the judgments of the English Courts
subsequent to The Commissioners of Inland Revenue v. His
Grace the Duke of Westminster 1935 All E.R. 259 and W.T.
Ramsay Ltd. v. Inland Revenue Commissioners (1981) 1
All E.R. 865 help us to understand the scope of Indo-
Mauritius DTAA. It needs to be...
