2013 (12) TMI 606

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..... nterest - The respondent assessee had a permanent place of business in India and, accordingly, submitted to the taxing jurisdiction of India and paid tax on its income except income from interest under Section 44BB of the Income Tax Act - The interest earned in India on the refund of income tax is not covered by Sub-Articles (1) & (2) of Article 12 of the said Treaty - Decided in favour of Revenue .....

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..... o charged shall not exceed 10 per cent of the gross amount of the interest. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other Contracting State in .....

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