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The ITAT held that income earned by the revocable foreign trust from investments in non-convertible debentures of Indian companies is not taxable in India. The trust, settled by a UAE-based entity and registered as an FII, was found exempt from Indian tax liability under the combined application of sections 61, 63, and 161 of the Income Tax Act, read with Article 24 of the India-UAE DTAA. The Tribunal relied on precedent where the Bombay HC quashed the AAR's order imposing tax on a similar trust. Consequently, the additions made by the AO were deleted, and the appeal filed by the trust was allowed, confirming that income accruing to such revocable foreign trusts is not chargeable to tax in India.
The ITAT held that income earned by the revocable foreign trust from investments in non-convertible debentures of Indian companies is not taxable in India. The trust, settled by a UAE-based entity and registered as an FII, was found exempt from Indian tax liability under the combined application of sections 61, 63, and 161 of the Income Tax Act, read with Article 24 of the India-UAE DTAA. The Tribunal relied on precedent where the Bombay HC quashed the AAR's order imposing tax on a similar trust. Consequently, the additions made by the AO were deleted, and the appeal filed by the trust was allowed, confirming that income accruing to such revocable foreign trusts is not chargeable to tax in India.
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