Monitoring Fees to DEG Bank Classified as 'Interest,' Exempt from Tax under Indo-German DTAA Article 11(3)(b.

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....TDS u/s 195 - Scope of the term 'Interest' - Monitoring fees paid by the assssee to DEG Bank, Germany qualified as ‘interest’ both under Income-tax Act, 1961 as well as the Double Taxation Avoidance Agreement between India & Germany and the payment made in question was not liable to Income tax under the Act in terms of the specific exemption granted under Article 11(3)(b) of the indo-German DTAA. - AT....