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2020 (7) TMI 276 - AT - Income TaxIncome accrued in India - Interest income from foreign currency loan and Securities - beneficial ownership of funds - Eligibility of exemption under Article 11(3)(c) of India - assessee placed on record the Tax Residency Certificate (for short “TRC”) issued by the Mauritius Revenue Authority evidencing the assessee‟s tax residence in Mauritius - HELD THAT:- We find that the said issue had been deliberated upon by the Tribunal in the assessee‟s own case for the preceding years [2020 (3) TMI 1242 - ITAT MUMBAI] wherein in the backdrop of identical fact pattern involved in the said years, it has consistently been held that as per Article 11(3)(c) of the India-Mauritius tax treaty the interest income would not be exigible to tax in India. - Decided in favour of assessee.
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