https://www.taxtmi.com/caselaws?id=360381 Treaty relief and domestic rate provisions governed taxation of FCCB-related receipts: interest and consultancy fee payable to a Cyprus resident were taxable in India only at 10% under the India-Cyprus treaty, read with section 90(2), and FCCB interest also fell within the 10% rate under section 115AC. For a non-resident, interest under sections 234B and 234C was not leviable where tax was deductible at source by the payer. Receipts from FCCBs were also examined on accrual in India, with the interest treated as covered by the statutory exclusion and the incentive fee held not to accrue or arise in India on the stated facts. TDS credit on FCCB interest required verification of deposit, deductee identity, and absence of duplicate claim. en-us Wed, 02 May 2018 00:00:00 +0530 Wed, 16 May 2018 06:44:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360381 Treaty relief and domestic rate provisions governed taxation of FCCB-related receipts: interest and consultancy fee payable to a Cyprus resident were taxable in India only at 10% under the India-Cyprus treaty, read with section 90(2), and FCCB interest also fell within the 10% rate under section 115AC. For a non-resident, interest under sections 234B and 234C was not leviable where tax was deductible at source by the payer. Receipts from FCCBs were also examined on accrual in India, with the interest treated as covered by the statutory exclusion and the incentive fee held not to accrue or arise in India on the stated facts. TDS credit on FCCB interest required verification of deposit, deductee identity, and absence of duplicate claim. Case-Laws Income Tax Wed, 02 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360381