Assessee Must Prove No Conduit Role for DTAA Exemptions on Interest Income in FII Activities.
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....Since, the assessee is claiming DTAA exemptions on the said interest income, the onus is on the assessee to demonstrate that the assessee is not a conduit company for the benefit of any third person and also no back to back transactions are involved in the FII activities of the bank - AT....
TaxTMI