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    <title>2012 (3) TMI 46 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>The Authority ruled that interest paid under a loan facility agreement guaranteed by a foreign entity was not eligible for tax exemption under the India-Sweden Double Taxation Avoidance Convention. The Authority clarified that guaranteeing a loan does not equate to extending or endorsing a loan, thus the interest payment was not exempt from taxation. However, the interest payment to the foreign entity through a designated bank was deemed not taxable in India under the Convention due to the Most Favoured Nation Clause in the Protocol, relieving the applicant from the obligation to withhold taxes under Section 195 of the Income-tax Act.</description>
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    <pubDate>Tue, 28 Feb 2012 00:00:00 +0530</pubDate>
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      <title>2012 (3) TMI 46 - AUTHORITY FOR ADVANCE RULINGS</title>
      <link>https://www.taxtmi.com/caselaws?id=211049</link>
      <description>The Authority ruled that interest paid under a loan facility agreement guaranteed by a foreign entity was not eligible for tax exemption under the India-Sweden Double Taxation Avoidance Convention. The Authority clarified that guaranteeing a loan does not equate to extending or endorsing a loan, thus the interest payment was not exempt from taxation. However, the interest payment to the foreign entity through a designated bank was deemed not taxable in India under the Convention due to the Most Favoured Nation Clause in the Protocol, relieving the applicant from the obligation to withhold taxes under Section 195 of the Income-tax Act.</description>
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      <pubDate>Tue, 28 Feb 2012 00:00:00 +0530</pubDate>
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