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ITAT grants treaty benefit to Cypriot entity being beneficial owner of interest income received on CCDs

September 11, 2019[2019] 109 83 (Mumbai)

INTERNATIONAL TAXATION: Where assessee, a company incorporated under laws of Cyprus, invested in Compulsorily Convertible Debentures (CCDs) in an Indian private limited company and received interest income thereon for its own exclusive benefit, and not for or on behalf of any other entity, it would be entitled to beneficial provisions of article 11 of DTAA between India and Cyprus
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