Interest Payments to CDB Exempt under Article 11(3) of India-China DTAA

ITO Vs Tata Teleservices Limited (ITAT Delhi)

The Income Tax Appellate Tribunal (ITAT) Delhi heard an appeal filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-43, dated October 30, 2023, related to Tata Teleservices Limited. The dispute concerned the tax treatment of interest payments made to China Development Bank (CDB). The Assessing Officer (AO) had previously concluded that the interest paid was taxable under Article 11(3) of the India-China Double Taxation Avoidance Agreement (DTAA), rejecting the taxpayer’s claim for exemption. The taxpayer,

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