Azadi Bachao Andolan

Challenge to CBDT Circular 789 of 2000 which directed acceptance of Mauritius Tax Residency Certificates as conclusive evidence of beneficial ownership for India-Mauritius DTAA benefits.

Validity of treaty shopping under bilateral tax treaties.

The SC upheld Circular 789 - TRC is sufficient evidence of residence; treaty shopping is not abuse if the treaty expressly permits it.

Treaty cannot be ignored on grounds of treaty shopping if the treaty itself permits residence-based benefits. (Later modified by the 2017 India-Mauritius protocol.)