https://www.taxtmi.com/caselaws?id=470107 Approved foreign-currency borrowings may qualify for the beneficial withholding rate under the India-Mauritius DTAA where the lender's residence and treaty eligibility are established and the transaction has government approval. The notes state that treaty relief, including a nil rate where applicable, does not require separate approval for lower or nil withholding merely because the borrowing was approved for concessional withholding. They further state that a borrower not acting as the foreign lender's representative assessee need not seek a refund for the lender; tax deducted under protest without a legal withholding obligation should be refunded with applicable interest. en-us Mon, 04 Aug 2025 00:00:00 +0530 Wed, 15 Jul 2026 18:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470107 Approved foreign-currency borrowings may qualify for the beneficial withholding rate under the India-Mauritius DTAA where the lender's residence and treaty eligibility are established and the transaction has government approval. The notes state that treaty relief, including a nil rate where applicable, does not require separate approval for lower or nil withholding merely because the borrowing was approved for concessional withholding. They further state that a borrower not acting as the foreign lender's representative assessee need not seek a refund for the lender; tax deducted under protest without a legal withholding obligation should be refunded with applicable interest. Case-Laws Income Tax Mon, 04 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470107