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Interest payable on FCCBs - There cannot be an exclusion clause if it is not falling within that provision but for the exclusion. Hence the presence of exclusion in Section 9(1)(v)(b) proves that it is falling within the ambit of deeming provision. - It has neither accrued nor arisen in India nor is deemed to accrue or arises in India in the hands of non-resident investors and therefore no TDS is deductible - Tri

Income Tax - Interest payable on FCCBs - There cannot be an exclusion clause if it is not falling within that provision but for the exclusion. Hence, the presence of exclusion in Section 9(1)(v)(b) pr .....

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