Court Upholds AO's Decision: No Deduction u/s 44C for Interest on External Loans; Taxed at 10% Under DTAA.

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....Deduction u/s 44C - interest on external commercial borrowing loans - No infirmity in the order of AO in not granting deduction u/s 44C of the act from the above income which is taxed under article 11 (2) of the DTAA on gross basis at the rate of 10%. As we hold that there is no need to go to Section 44C of the act in this case, reliance placed by the assessee on the several judicial precedents with respect to the definition of meaning of total income/ adjusted income is not relevant. - AT....