Interest limitation carve-out excludes debt from permanent establishments of foreign banks from interest disallowance under amended rules. The amendment provides that the interest limitation will not apply to interest paid in respect of debt issued by a lender which is a permanent ... Summary
Interest limitation carve-out excludes debt from permanent establishments of foreign banks from interest disallowance under amended rules.
The amendment provides that the interest limitation will not apply to interest paid in respect of debt issued by a lender which is a permanent establishment of a non-resident engaged in banking in India, thereby carving out loans from branches of foreign banks from the section 94B restriction and avoiding application of the earnings based disallowance to such debt.
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