https://www.taxtmi.com/forum/issue?id=5181 Whether payments by Mitsui Prime Advanced Composites India Pvt Ltd to Mitsui Chemical Inc., Japan for loan-related obligations attract India-Japan DTAA treatment for loan guarantee fees and whether tax must be withheld at source. The advisory notes that withholding obligations arise if the payments constitute taxable income sourced to India and that TDS should be considered under domestic withholding provisions read with income attribution rules and the DTAA; a detailed factual and legal examination is required for a conclusive view. en-us Mon, 14 Jan 2013 11:21:48 +0530 Thu, 23 Jan 2025 15:57:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=5181 Whether payments by Mitsui Prime Advanced Composites India Pvt Ltd to Mitsui Chemical Inc., Japan for loan-related obligations attract India-Japan DTAA treatment for loan guarantee fees and whether tax must be withheld at source. The advisory notes that withholding obligations arise if the payments constitute taxable income sourced to India and that TDS should be considered under domestic withholding provisions read with income attribution rules and the DTAA; a detailed factual and legal examination is required for a conclusive view. Discussion-Forum Income Tax Mon, 14 Jan 2013 11:21:48 +0530 https://www.taxtmi.com/forum/issue?id=5181