55 Business Authority (MOBA) in 1993, thereby creating a favourable regulatory framework for offshore investments. This development coincided with India’s economic liberalization policy of 1991-1992, further accelerating foreign capital inflows through Mauritius. CBDT Circular No. 682 dated 30.02.1994 12.4. Upon becoming aware that the Treaty was being misused, as the ultimate beneficiaries of the investments were often residents