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2004 (5) TMI 56 - AUTHORITY FOR ADVANCE RULINGSApplicant, a closely-held private limited company incorporated in India, engaged in the business of development of properties and allied activities, allotted partly convertible debentures to a company incorporated in Mauritius - Since exemption from tax has not been granted to the applicant either under Income-tax Act, 1961, or under the DTAA, the applicant is required to deduct tax at source in accordance with section 193 on interest paid or credited to the account of the foreign company
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