https://www.taxtmi.com/caselaws?id=6578 Advance rulings may be sought on the tax liability of a non-resident lender where the applicant undertakes to bear the Indian tax burden, so the application was maintainable. Interest paid to a non-resident bank with no permanent establishment in India was treated as interest arising in India under the India-Singapore treaty and remained taxable in India within the treaty limits. On that basis, the payer was required to withhold tax at source under section 195. The ruling confirms that treaty sourcing rules and domestic withholding obligations can apply together to cross-border interest payments. en-us Mon, 21 Feb 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6578 Advance rulings may be sought on the tax liability of a non-resident lender where the applicant undertakes to bear the Indian tax burden, so the application was maintainable. Interest paid to a non-resident bank with no permanent establishment in India was treated as interest arising in India under the India-Singapore treaty and remained taxable in India within the treaty limits. On that basis, the payer was required to withhold tax at source under section 195. The ruling confirms that treaty sourcing rules and domestic withholding obligations can apply together to cross-border interest payments. Case-Laws Income Tax Mon, 21 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6578