On 7 October 2003, a two-judge bench of Justices Ruma Pal and B.N. Srikrishna reversed the Delhi High Court and upheld CBDT Circular No. 789 of 13 April 2000 — which had directed assessing officers to treat a Tax Residency Certificate issued by Mauritian authorities as sufficient evidence of residence and beneficial ownership for the purposes of the India–Mauritius Double Taxation Avoidance Agreement. The bench held that treaty shopping is not per se illegal in the absence of an express limitation-of-benefits clause, that the CBDT acted within its Section 119 power, and that Chinnappa Reddy J.'s anti-avoidance observations in McDowell (1985) were obiter and did not displace the Westminster principle in Indian law. A digest of the bench, the architecture of the DTAA, the doctrinal contribution, and the post-judgment arc through the 2016 Protocol, GAAR, and Tiger Global.