https://www.taxtmi.com/caselaws?id=390605 Interest earned by a Mauritius-resident bank from foreign currency loans and debt securities was held exempt under Article 11(3)(c) of the India-Mauritius treaty because the assessee was treated as the beneficial owner carrying on bona fide banking business, supported by its Tax Residency Certificate and CBDT Circular No. 789. The income was therefore not taxable in India. As the underlying interest was not taxable and tax was expected to be deducted at source, interest under section 234B was held not leviable. The assessee obtained relief on both substantive taxability and consequential interest, and the Revenue's appeal failed. en-us Fri, 20 Dec 2019 00:00:00 +0530 Tue, 07 Jan 2020 08:10:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390605 Interest earned by a Mauritius-resident bank from foreign currency loans and debt securities was held exempt under Article 11(3)(c) of the India-Mauritius treaty because the assessee was treated as the beneficial owner carrying on bona fide banking business, supported by its Tax Residency Certificate and CBDT Circular No. 789. The income was therefore not taxable in India. As the underlying interest was not taxable and tax was expected to be deducted at source, interest under section 234B was held not leviable. The assessee obtained relief on both substantive taxability and consequential interest, and the Revenue's appeal failed. Case-Laws Income Tax Fri, 20 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390605