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2005 (2) TMI 18 - AAR - Income TaxApplicant, a resident company, has taken a loan of US $ 34,00,000 from Rabobank of Singapore - As per para, (c) of schedule 5 of the loan agreement detailing with general terms and conditions, the tax liability of the Rabobank (a non-resident) is to be borne by the applicant and payment of interest is to be made net of all taxes – held that interest paid to M/s. Rabobank will constitute income in the hands of the non-resident and TDS under section 195 of the Income-tax Act, 1961, is deductible
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