https://www.taxtmi.com/caselaws?id=296776 Interest on non-convertible debentures was treated as income from an investment in debt instruments, not as interest on a loan granted by a bank or similar financial institution. The AAR applied the ordinary meaning of "loan" and "grant" and found that the transaction was not a bilateral lending arrangement within article 11(2)(a) of the India-Singapore tax treaty. As a result, the concessional rate under article 11(2)(a) was unavailable, but the applicant could claim the more beneficial treaty rate under article 11(2)(b). The interest was therefore taxable at 15% under article 11(2)(b), with tax deduction at source required at that rate under section 195 of the Income-tax Act, 1961. en-us Wed, 24 Jul 2019 00:00:00 +0530 Thu, 05 Aug 2021 20:47:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296776 Interest on non-convertible debentures was treated as income from an investment in debt instruments, not as interest on a loan granted by a bank or similar financial institution. The AAR applied the ordinary meaning of "loan" and "grant" and found that the transaction was not a bilateral lending arrangement within article 11(2)(a) of the India-Singapore tax treaty. As a result, the concessional rate under article 11(2)(a) was unavailable, but the applicant could claim the more beneficial treaty rate under article 11(2)(b). The interest was therefore taxable at 15% under article 11(2)(b), with tax deduction at source required at that rate under section 195 of the Income-tax Act, 1961. Case-Laws Income Tax Wed, 24 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296776