OrbitaxIndia Income Tax Appellate Tribunal Holds Interest "Payable" is Not Taxable Interest "Paid" Under Tax Treaty with Cyprus
|Treaty Development|India-Cyprus
The Delhi Income Tax Appellate Tribunal (ITAT) issued an order on 2 September 2021 concerning the appeal of a transfer pricing adjustment on deemed interest payable and whether the deemed interest payable is taxable under Article 11 (Interest) of the Cyprus-India tax treaty. The case involved a company incorporated in Cyprus that had subscribed to fully convertible debentures (FCDs) issued by m…
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