Tax treatment of exchangeable bonds: interest subject to withholding, dividends taxed per law, exchange not a capital gains event. Interest on Foreign Currency Exchangeable Bonds before exercise of the exchange option is subject to deduction of tax at source; dividend on the exchanged portion is taxable under the same withholding provision; exchange of such bonds into shares does not give rise to capital gains taxable in India; transfers made outside India between non resident investors do not create capital gains liability in India.
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Provisions expressly mentioned in the judgment/order text.
Tax treatment of exchangeable bonds: interest subject to withholding, dividends taxed per law, exchange not a capital gains event.
Interest on Foreign Currency Exchangeable Bonds before exercise of the exchange option is subject to deduction of tax at source; dividend on the exchanged portion is taxable under the same withholding provision; exchange of such bonds into shares does not give rise to capital gains taxable in India; transfers made outside India between non resident investors do not create capital gains liability in India.
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