Interest Income on ECB taxable at rates provided in Article 11 of Indo-Netherlands Tax Treaty

DCIT Vs Cooperative Rabobank UA (ITAT Mumbai) ITAT Mumbai held that interest income on External Commercial Borrowings (ECB) is taxable at tax rate provided under Article 11 of Indo Netherlands Tax Treaty and not taxable in terms of Article 7 of the Tax Treaty. Facts- AO in the course of assessment proceedings observed from the ITS (Individual Transaction System from ITD) details of the assessee that assessee had an undisclosed TDS credit amounting to Rs.6,96,33,878/-. Assessee explained the difference, however, on without prejudice basis submitted, that the difference in income could be brough...