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2008 (10) TMI 21 - AAR - Income TaxApplicant borrow money from LMCC, USA by issuing fully convertible Bonds - non-resident’s liability - interest paid to LMCC upto the date of conversion of bonds into equity shares has to be treated as interest as per Section 2(28A) and Article 11 of the India-USA DTAA and accordingly, liable to be taxed as ‘income’ of LMCC under the Act and under Art.11.2 - interest payments cannot be construed as dividend income of LMCC - Under Section 195(1), the applicant is liable to deduct tax at source
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