Department Must Substantiate Shell Company Claim Despite: ITAT Delhi
Even though the department had the authority to dispute the residential status of the assessee merely on the strength of the Tax Residency Certificate (TRC), it was incumbent upon the department to make a proper inquiry and to establish the fact that the party claiming benefit and the strength of the TRC was a shell or conduit company.
State Of Madhya Pradesh Madhya Pradesh New Delhi Dilip Kumar Lakhmani Mewal Das Azadi Bachao Andolan
Source: taxguru.in