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Where not only the bonds were raised outside India, but the interest payments were also made to non-residents outside India from a bank account held by the assessee outside India, no part of the transaction relating to payment of interest has taken place in India. Therefore, it cannot be said that the interest payment made to non-residents has accrued or arisen in India u/s 9.

Income Tax - Where not only the bonds were raised outside India, but the interest payments were also made to non-residents outside India from a bank account held by the assessee outside India, no part of the transaction relating to payment of interest has taken place in India. Therefore, it cannot be said that the interest payment made to non-residents has accrued or arisen in India u/s 9. - TMI Updates - Highlights .....

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