Tax treaty shopping is a major issue for many countries because it causes erosion of the country's

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Tax treaty shopping is a major issue for many countries because it causes erosion of the country's tax base. Review the following article, which describes the case of Commissioner of Income Tax vs Jsh (Mauritius) Ltd (High Court of Bombay) (28 July, 2017). https://www.mondaq.com/india/capital-gains-tax/616876/azadi-saves-the-day-court-rules-in-favour-of-mauritian-resident-company

Create a case brief that identifies the following components:

• The material facts • Legal issue

• The court's holding, and

• The rationale for the holding.

State whether you agree with the holding and why.