E* TRADE MAURITIUS LTD Vs. DIT

JUDGEMENT

(1.) THIS application for advance ruling has been filed by a non' resident company under Section 245Q(1) of the Income -tax Act (hereinafter referred as IT Act). The following facts are stated in the application:

(2.) THE applicant has formulated the following questions for seeking advance ruling:

(3.) NOW , let us see the relevant provision in the DTAA i.e. Article 13: