TMI BlogCorporate/bank guarantee recharge - nature of receipt - India U.K. DTAA - this payment does not fall...Corporate/bank guarantee recharge - nature of receipt - India U.K. DTAA - this payment does not fall within the expression of interest and in view of Clause 3 of Article 23 of the Treaty, in the absence of any specific provision dealing with corporate/bank guarantee recharge, the same has to be taxed in India as per the provisions of the Income tax Act, 1961 - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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