Section 90 – Tax Residency Certificate (TRC) issued by other country is to be accepted as the basis of benefits under DTAA. AO cannot go behind TRC issued by another country & issue re-assessment notice to determine issues of residential status, treaty eligibility and legal ownership.
Blackstone Capital Partners (Singapore) Vi Fdi Three Pte. Ltd. v. ACIT – [2023] 146 taxmann.com 569 (Delhi).