Interest limitation exemption: debt interest from a lender that is the India permanent establishment of a non-resident bank is excluded. The amendment excludes application of the interest limitation rule to interest paid on debt issued by a lender which is the permanent establishment in India of a non-resident engaged in the business of banking, thereby creating an exception to the deduction restraint where the creditor is a bank's India presence.
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Provisions expressly mentioned in the judgment/order text.
Interest limitation exemption: debt interest from a lender that is the India permanent establishment of a non-resident bank is excluded.
The amendment excludes application of the interest limitation rule to interest paid on debt issued by a lender which is the permanent establishment in India of a non-resident engaged in the business of banking, thereby creating an exception to the deduction restraint where the creditor is a bank's India presence.
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