https://www.taxtmi.com/caselaws?id=325645 Amounts received on without recourse discounting of bills of exchange and promissory notes were treated as discounting charges, not interest, because the transaction did not involve money borrowed or debt incurred by the recipient within section 2(28A). The Tribunal followed its earlier rulings in the assessee's own case and the jurisdictional High Court, and rejected the Revenue's objections based on the surrounding commercial arrangement and RBI/FEMA references. As the non-resident assessee had no permanent establishment in India, the receipts were not taxable in India as interest income under the treaty. en-us Tue, 15 Mar 2016 00:00:00 +0530 Fri, 25 Mar 2016 09:35:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325645 Amounts received on without recourse discounting of bills of exchange and promissory notes were treated as discounting charges, not interest, because the transaction did not involve money borrowed or debt incurred by the recipient within section 2(28A). The Tribunal followed its earlier rulings in the assessee's own case and the jurisdictional High Court, and rejected the Revenue's objections based on the surrounding commercial arrangement and RBI/FEMA references. As the non-resident assessee had no permanent establishment in India, the receipts were not taxable in India as interest income under the treaty. Case-Laws Income Tax Tue, 15 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325645