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    <title>2018 (12) TMI 1511 - ITAT DELHI</title>
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    <description>Interest on an income-tax refund was treated as income from other sources under the applicable DTAA article because it was not effectively connected with the permanent establishment in India; the treaty benefit was applied and the receipt was taxed on that basis. Interest earned on foreign bank accounts, and foreign exchange gain arising on reinstatement of foreign balances kept outside India, were held not taxable in India on the facts found. The Tribunal followed its earlier decision on identical facts and deleted the related additions, applying treaty characterisation and territorial nexus principles.</description>
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      <link>https://www.taxtmi.com/caselaws?id=372742</link>
      <description>Interest on an income-tax refund was treated as income from other sources under the applicable DTAA article because it was not effectively connected with the permanent establishment in India; the treaty benefit was applied and the receipt was taxed on that basis. Interest earned on foreign bank accounts, and foreign exchange gain arising on reinstatement of foreign balances kept outside India, were held not taxable in India on the facts found. The Tribunal followed its earlier decision on identical facts and deleted the related additions, applying treaty characterisation and territorial nexus principles.</description>
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