https://www.taxtmi.com/caselaws?id=396607 The ITAT dismissed the revenue's appeal, affirming that the assessee's interest income from foreign currency loans and securities was not taxable in India under Article 11(3)(c) of the India-Mauritius DTAA. The ITAT upheld the CIT(A)'s directive to follow previous ITAT decisions, validating the assessee's beneficial ownership and exemption claims. The ITAT also confirmed the applicability of CBDT Circular No. 789 to interest income, aligning with the Bombay HC's judgment in Universal International Music B.V., which considered the Tax Residency Certificate sufficient evidence of beneficial ownership, thereby supporting the exemption under the DTAA. en-us Wed, 08 Jul 2020 00:00:00 +0530 Fri, 08 Nov 2024 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396607 The ITAT dismissed the revenue's appeal, affirming that the assessee's interest income from foreign currency loans and securities was not taxable in India under Article 11(3)(c) of the India-Mauritius DTAA. The ITAT upheld the CIT(A)'s directive to follow previous ITAT decisions, validating the assessee's beneficial ownership and exemption claims. The ITAT also confirmed the applicability of CBDT Circular No. 789 to interest income, aligning with the Bombay HC's judgment in Universal International Music B.V., which considered the Tax Residency Certificate sufficient evidence of beneficial ownership, thereby supporting the exemption under the DTAA. Case-Laws Income Tax Wed, 08 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396607