TMI BlogTDS u/s 195 - There should be a “debt claim and ‘form’ such claim income should arise to qualify as...TDS u/s 195 - There should be a “debt claim and ‘form’ such claim income should arise to qualify as ‘interest’. Thus the word ‘debt claim “predicate the existence of debtor – creditor relationship [lender – borrower]. That relationship can arise only when there is a provision of capital. - Guarantee fee paid by the assessee to Netherlands company cannot be covered in the definition of interest as per Article 11 of The DTAA.. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
