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India and Mauritius had struck a double taxation avoidance convention way back in 1983 and this was the agreement based on which investors both foreign institutional investors and foreign direct investors who invest in you know large companies for manufacturing or services were investing through Mauritius basically they would set up companies in Mauritius and the company headquartered in Mauritius or register in Mauritius would then invest into Indian instruments or Indian set up Indian corporations so these investors benefited from the low taxation prevailing in Mauritius and because of the DTA enabling them to not have to pay capital gains on the capital gain that accrued for a transaction in India and they only had to pay in Mauritius there was no capture of revenue from these companies for the investments that they were making in India now while Mauritius may not have minded this Indian tax tax authorities were obviously not very pleased with the outcome of what was happening beca