Section 90 of the Income Tax Act, 1961 — DTAA — Assessee, a fund established in Netherlands, being a trustee of INGEMEF, a tax transparent entity, whose beneficiaries are taxable entities in Netherlands,  benefit of treaty protection under the Indo Netherlands DTAA is available to assessee in respect of Capital gains arising on sale of shares in India — ING Bewaar Maatschappij I BV vs. Deputy Commissioner of income tax [2019] 202 TTJ (Mumbai) 1049