The Mumbai Income Tax Appellate Tribunal recently issued a decision concerning whether a certificate of residence issued by the Mauritius authority is sufficient proof of beneficial ownership. The case involved HSBC Bank (Mauritius) Ltd. (HSBC), which derived interest income from investments in Indian debt securities. Based on paragraph 3(c) of Article 11 (Interest) of the 1982 India-Mauritius tax treaty (prior to amendment by 2016 protocol), HSBC claimed it was exempt from withholding tax on the interest income. The provision of the treaty provided that interest arising in a Contracting State shall be exempt from tax in that State provided it...