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    <title>2019 (1) TMI 1688 - ITAT MUMBAI</title>
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    <description>A Mauritian residence certificate, read with CBDT Circular No. 789, was treated as sufficient to establish beneficial ownership and treaty entitlement for interest on foreign currency loans under Article 11(3)(c) of the India-Mauritius tax treaty, so the income was held exempt from Indian taxation and the addition was deleted. The Tribunal also held that interest under section 234B could not be levied on the non-resident recipient where tax was deductible at source from the payer, and the levy was deleted.</description>
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      <description>A Mauritian residence certificate, read with CBDT Circular No. 789, was treated as sufficient to establish beneficial ownership and treaty entitlement for interest on foreign currency loans under Article 11(3)(c) of the India-Mauritius tax treaty, so the income was held exempt from Indian taxation and the addition was deleted. The Tribunal also held that interest under section 234B could not be levied on the non-resident recipient where tax was deductible at source from the payer, and the levy was deleted.</description>
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