TDS on interest paid to China Development Bank- HC dismisses Stay Application

Tata Teleservices Limited Vs CIT (Delhi High Court)

Learned counsel for the petitioner states that the disputed demand has arisen on account of the failure of the petitioner to deduct tax at source on the interest payments made to China Development Bank (hereinafter referred to as ‘CDB’), which as per the petitioner was a bank wholly owned by the Government of China. He submits that as per article 11(3) of India-China Double Taxation Avoidance Agreement (DTAA), any interest income which arises in India and is payable to

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