https://www.taxtmi.com/caselaws?id=175162 Upfront appraisal fees received before any debt came into existence were not interest under section 2(28A) or Article 12 of the India-UK DTAA because they lacked a debt-claim nexus, but front-end fees linked to debt investments were treated as interest income within both the statutory and treaty definitions. Directors' fees paid for attending board meetings as nominee directors were not fees for technical services, as no technical knowledge, skill, or know-how was made available under Article 13(4). Capital gains from transfer of shares of an Indian company were taxable in India under section 9(1)(i), since such shares were treated as rights in an Indian capital asset situated in India. en-us Thu, 25 Feb 2010 00:00:00 +0530 Mon, 09 Nov 2015 14:47:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175162 Upfront appraisal fees received before any debt came into existence were not interest under section 2(28A) or Article 12 of the India-UK DTAA because they lacked a debt-claim nexus, but front-end fees linked to debt investments were treated as interest income within both the statutory and treaty definitions. Directors' fees paid for attending board meetings as nominee directors were not fees for technical services, as no technical knowledge, skill, or know-how was made available under Article 13(4). Capital gains from transfer of shares of an Indian company were taxable in India under section 9(1)(i), since such shares were treated as rights in an Indian capital asset situated in India. Case-Laws Income Tax Thu, 25 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175162