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    <title>2024 (1) TMI 1403 - BOMBAY HIGH COURT</title>
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    <description>Interest income earned in India by a Mauritius-resident bank was treated as exempt under Article 11(3)(c) of the Indo-Mauritius tax treaty because the recipient was a bank carrying on bona fide banking business in Mauritius. The relevant condition was residence in the other Contracting State and genuine banking activity there; a separate Reserve Bank of India banking licence, or banking operations in India, was not required for the treaty exemption. The tax authorities had already accepted that the assessee carried on bona fide banking business in Mauritius, so the exemption applied.</description>
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      <description>Interest income earned in India by a Mauritius-resident bank was treated as exempt under Article 11(3)(c) of the Indo-Mauritius tax treaty because the recipient was a bank carrying on bona fide banking business in Mauritius. The relevant condition was residence in the other Contracting State and genuine banking activity there; a separate Reserve Bank of India banking licence, or banking operations in India, was not required for the treaty exemption. The tax authorities had already accepted that the assessee carried on bona fide banking business in Mauritius, so the exemption applied.</description>
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