TDS Not Applicable on Interest from FCCBs: Income Excluded u/s 9(1)(v)(b) and Section 5(2) of Income Tax Act.

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....TDS u/s.196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under the exclusion clause of income deemed to accrue or arise in India u/s 9(1)(v)(b) of the Act, it cannot fall within the ambit of income accrued and arisen in India, and hence, the same cannot be said to be covered u/s 5(2) - Since the income is taxable, question of TDS does not arise - AT....