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    In a recent ruling the Authority for Advance Rulings (AAR) has held that interest on debentures paid to an investor, who is a resident of Mauritius, is subject to withholding tax in India, unless it is specifically exempted.

    The AAR had been approached by an Indian company for ascertainment of its liability to deduct tax at source for payment of interest on partly-convertible debentures to a company incorporated in Mauri

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    In a recent ruling the Authority for Advance Rulings (AAR) has held that interest on debentures paid to an investor, who is a resident of Mauritius, is subject to withholding tax in India, unless it is specifically exempted.

    The AAR had been approached by an Indian company for ascertainment of its liability to deduct tax at source for payment of interest on partly-convertible debentures to a company incorporated in Maur

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    nterest on debentures paid to an investor, who is a resident of Mauritius, is subject to withholding tax in India, unless it is specifically exempted.

    The AAR had been approached by an Indian company for ascertainment of its liability to deduct tax at source for payment of interest on partly-convertible debentures to a company incorporated in Maur

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    ss it is specifically exempted.

    The AAR had been approached by an Indian company for ascertainment of its liability to deduct tax at source for payment of interest on partly-convertible debentures to a company incorporated in Maur

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    ity to deduct tax at source for payment of interest on partly-convertible debentures to a company incorporated in Mauritius. The Indian company argued that the interest income payable was exempt from tax in India owing to Article 11(4) of the Indo-Mauritius tax treaty. In terms of Article 11(4) of the treaty, interest arising in Country A derived and beneficially owned by any person who is a resident of Country B shall be exempt from tax in Country A subject to and to the extent approved by the Government of Country A provided that the transaction giving rise to the debt claim has been

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