AAR couldn't reject application without explaining how transaction via Mauritius route was made for

IT/ILT : AAR could not reject application filed by assessee, a Mauritius based company, seeking advance ruling on question as to whether capital gain arising on sale of shares of Indian company to another foreign company was taxable in India in terms of article 13(4) of India-Mauritius DTAA taking a view that said transaction was prima facie designed for tax avoidance without assigning any reasons therefor