October 2019

Article 11 of India-Cyprus DTAA Interest earned by Cyprian company from investment in CCDs which were funded by parent company qualified for lower rate under Article 11 of India-Cyprus DTAA since, on facts, the Cyprian company had indicia (marks or signs) of beneficial owner of interest income

Geeta Jani | Dhishat B. Mehta
Chartered Accountants

3. TS-523-ITAT-2019 (Mum.) Golden Bella Holdings Ltd. vs. DCIT ITA No.: 6958/Mum/2017 A.Y.: 2013-14 Date of order: 28th August, 2019

 

Article 11 of India-Cyprus DTAA Interest earned by Cyprian company from investment in CCDs which were funded by parent c

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