Interest Income as ‘Beneficial owner’ cannot be taxed under Article 11(3)(c) of India-Mauritius Tax Treaty

DCIT Vs HSBC Bank (Mauritius) Ltd. (ITAT Mumbai)

The issue under consideration is whether as per India-Mauritius DTAA, Interest Income from Foreign Currency loan and Securities would be eligible to tax in India?

In the present case, the assessee, is a limited liability company incorporated, registered and a tax resident in Mauritius are a Foreign Institutional Investor (FII) duly registered as such by the Securities and Exchange Board of India (SEBI). The assessee had e-fi

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