https://www.taxtmi.com/caselaws?id=241440 Under the India-UAE DTAA, interest income was governed by the specific treaty article for interest rather than the general business profits article, so the source State could tax the interest only within the treaty cap of 12.5% of gross interest. The treaty definition of tax was read to include surcharge, and education cess was treated as of the same nature as surcharge. On that basis, the 12.5% cap under Article 11(2) was inclusive of surcharge and education cess, and no separate levy of either was permissible. en-us Wed, 27 Feb 2013 00:00:00 +0530 Thu, 28 May 2026 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241440 Under the India-UAE DTAA, interest income was governed by the specific treaty article for interest rather than the general business profits article, so the source State could tax the interest only within the treaty cap of 12.5% of gross interest. The treaty definition of tax was read to include surcharge, and education cess was treated as of the same nature as surcharge. On that basis, the 12.5% cap under Article 11(2) was inclusive of surcharge and education cess, and no separate levy of either was permissible. Case-Laws Income Tax Wed, 27 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241440