https://www.taxtmi.com/caselaws?id=215331 Interest on Government securities accrues only on the contractual payment dates, because the holder has no enforceable right to receive interest earlier; no notional or broken-period accrual arises merely from year-end holding or sale before the next due date. The sale surplus on such securities is not "interest" under Article 11(4) of the India-Cyprus tax treaty, as it results from transfer of the asset rather than from the debt-claim itself; it is taxable, if at all, as capital gains under Article 14(4). Treaty protection therefore applied to the assessee, and the tax additions were unsustainable. en-us Mon, 09 Jul 2012 00:00:00 +0530 Wed, 20 May 2026 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215331 Interest on Government securities accrues only on the contractual payment dates, because the holder has no enforceable right to receive interest earlier; no notional or broken-period accrual arises merely from year-end holding or sale before the next due date. The sale surplus on such securities is not "interest" under Article 11(4) of the India-Cyprus tax treaty, as it results from transfer of the asset rather than from the debt-claim itself; it is taxable, if at all, as capital gains under Article 14(4). Treaty protection therefore applied to the assessee, and the tax additions were unsustainable. Case-Laws Income Tax Mon, 09 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215331