India's Income Tax Appellate Tribunal (ITAT) recently issued a decision concerning the taxation of income from Indian depository receipts (IDRs) as Indian-source income when the underlying value of the instruments is derived from foreign companies. The case involved a tax resident of Mauritius that invested in IDRs issued by the India Branch of Standard Chartered Bank (SCB), the underlying assets of which are shares of SCB UK. During the 2014-15 financial year (2015-16 assessment year), the Mauritius investor received payments amounting to INR 97.4 million from SCB India for the IDRs. The Indian tax authority determined that the payments constituted...