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Income Tax - Highlights / Catch Notes

Home Highlights June 2020 Year 2020 This

TDS u/s 195 - There should be a “debt claim and ‘form’ such ...

Income Tax

June 18, 2020

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..

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