https://www.taxtmi.com/caselaws?id=207662 Interest paid to a French lender and its assignee was held not taxable in India under the India-France tax treaty, as modified by the Most Favoured Nation clause in the protocol. Although mere COFACE insurance was not treated as an endorsement of the credit on the treaty text alone, later OECD-member treaty practice was used to extend the narrower source-taxing rule to insured credit, giving the applicant treaty relief. Because the interest was not chargeable to tax in India, the applicant was also held under no obligation to deduct tax at source on the payments. en-us Mon, 05 Dec 2011 00:00:00 +0530 Tue, 15 May 2012 16:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207662 Interest paid to a French lender and its assignee was held not taxable in India under the India-France tax treaty, as modified by the Most Favoured Nation clause in the protocol. Although mere COFACE insurance was not treated as an endorsement of the credit on the treaty text alone, later OECD-member treaty practice was used to extend the narrower source-taxing rule to insured credit, giving the applicant treaty relief. Because the interest was not chargeable to tax in India, the applicant was also held under no obligation to deduct tax at source on the payments. Case-Laws Income Tax Mon, 05 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207662