Concessional interest withholding: foreign-currency deposits used to subscribe long-term infrastructure bonds deemed borrowings by issuer for tax treatment. The amendment treats foreign-currency sums deposited by a non-resident (not a company) or a foreign company into a bank account opened solely to fund subscription to long-term infrastructure bonds, which are converted into rupees and used to subscribe to bonds issued by a specified Indian company, as borrowings made by that specified company in foreign currency for the purposes of section 194LC(2). It also defines 'designated account' as an account opened solely for deposit of such foreign currency and its utilisation for subscription payments.
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Provisions expressly mentioned in the judgment/order text.
Concessional interest withholding: foreign-currency deposits used to subscribe long-term infrastructure bonds deemed borrowings by issuer for tax treatment.
The amendment treats foreign-currency sums deposited by a non-resident (not a company) or a foreign company into a bank account opened solely to fund subscription to long-term infrastructure bonds, which are converted into rupees and used to subscribe to bonds issued by a specified Indian company, as borrowings made by that specified company in foreign currency for the purposes of section 194LC(2). It also defines "designated account" as an account opened solely for deposit of such foreign currency and its utilisation for subscription payments.
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