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Interest
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....ner of the interest the tax so charged shall not exceed 10 per cent of gross amount of the interest.] 3. Notwithstanding the provisions of paragraph 2: (a) the Government of one of the States shall be exempt from tax in the other State in respect of interest derived directly or indirectly by that Government from that other State; (b) interest arising in one of the States and p....
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....countries); - all other institutions as may be agreed from time to time between the competent authorities of the States; (b) in the case of India, the Government of India and shall include: - a political sub-division ; - a local authority ; - the Reserve Bank of India (Central Bank) ; - the Export-Import Bank of India ; - such institut....
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....t for the purpose of this Article. 7. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of one of the States, carries on business in the other State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and ....
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.... establishment or fixed base is situated. 9. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provi....