https://www.taxtmi.com/caselaws?id=32087 RBI permission for issue of debentures and payment of interest was not Government approval for tax exemption under the Income-tax Act or under Article 11(4) of the India-Mauritius treaty. The AAR found no separate exemption authorisation from the Department of Economic Affairs or Department of Revenue, and held that treaty relief required a transaction-specific exemption granted by the competent tax authority, not merely foreign-exchange approval. As neither domestic-law exemption nor treaty-based exemption was available, tax had to be withheld on the interest payment under section 193 of the Income-tax Act. en-us Mon, 24 May 2004 00:00:00 +0530 Thu, 15 Jan 2009 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32087 RBI permission for issue of debentures and payment of interest was not Government approval for tax exemption under the Income-tax Act or under Article 11(4) of the India-Mauritius treaty. The AAR found no separate exemption authorisation from the Department of Economic Affairs or Department of Revenue, and held that treaty relief required a transaction-specific exemption granted by the competent tax authority, not merely foreign-exchange approval. As neither domestic-law exemption nor treaty-based exemption was available, tax had to be withheld on the interest payment under section 193 of the Income-tax Act. Case-Laws Income Tax Mon, 24 May 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32087