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Case lawAdvance Ruling › DLJMB Mauritius Investment Company v CIT
Advance RulingHelps taxpayerSuperseded by amendments.10(15)s.245Qs.245R(2)DTAA art 4DTAA art 11DTAA art 13DTAA art 22

DLJMB Mauritius Investment Company v CIT

We are a Mauritius company set up to channel US money into Indian securities. Are we entitled to the India-Mauritius treaty on our dividends, interest and capital gains?

We are a Mauritius company set up to channel US money into Indian securities. Are we entitled to the India-Mauritius treaty on our dividends, interest and capital gains?

Yes, in substance. The Authority ruled that DLJMB Mauritius Investment Company was resident in Mauritius within the meaning of article 4 of the India-Mauritius agreement and entitled to the benefits flowing from it, notwithstanding that it had been placed in Mauritius partly for regulatory convenience and partly for the treaty. Capital gains on the transfer of securities, long-term and short-term, were not taxable in India by force of article 13. Income from units of mutual funds fell to the residuary article and was not taxable in India. Interest on approved debt instruments was exempt only so far as Indian law provided. Two questions were withdrawn or not pressed.

Pronounced by the Authority for Advance Rulings (S. Ranganathan, J. (Chairman) and Subhash C. Jain, Member) on 1997-07-16, reported as [1997] 228 ITR 268 (AAR). It bears on section 10(15), section 245Q, section 245R(2), section DTAA art 4, section DTAA art 11, section DTAA art 13, section DTAA art 22 of the Income Tax Act 1961, in Residence & Treaty Benefit and Capital Gains matters.

Superseded by amendment. The capital gains holding has been reversed by treaty. The Protocol amending the India-Mauritius Convention was signed at Port Louis on 10 May 2016: shares acquired before 1 April 2017 remain grandfathered, gains on shares acquired on or after that date are taxable in India, tax was limited to 50 per cent of the domestic rate for the transition period from 1 April 2017 to 31 March 2019 subject to limitation of benefits conditions, and the full domestic rate applies from 2019-20. The same Protocol added a limitation of benefits article aimed at treaty shopping. On the residence limb, the Supreme Court in Union of India v. Azadi Bachao Andolan (7 October 2003) upheld the Mauritius residence certification approach against a treaty-shopping challenge, so that part of the reasoning was not undermined judicially. The Authority itself was replaced by the Board for Advance Rulings from 1 September 2021 (Finance Act 2021; Notification 96/2021), whose rulings are appealable to the High Court under section 245W, and the Income-tax Act 1961 was replaced by the Income-tax Act 2025 from 1 April 2026.

Why it matters

This is an early and much-cited AAR treatment of Mauritius residence, and it matters chiefly as a marker of where the law stood before it changed. The Authority accepted residence under article 4 and gave effect to article 13, which then reserved capital gains on Indian securities to Mauritius. Its qualification on interest is the part most often overlooked: exemption under article 11 for approved debt transactions ran only so far as Indian domestic law provided an exemption, and subject to the limits Indian law set. The capital gains position has since been reversed by treaty. The Protocol signed at Port Louis on 10 May 2016 gave India the right to tax gains on shares acquired on or after 1 April 2017, with a transitional half rate to 31 March 2019, and added a limitation of benefits article.

Binding only on the applicant who sought it, in respect of the transaction the ruling was sought on, and on the Principal Commissioner or Commissioner and the authorities subordinate to him in respect of that applicant and that transaction — and only until the law or the facts change (section 245S). It binds nobody else. The Tribunal and the courts nonetheless treat a considered ruling as persuasive, which is why practitioners cite them.

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