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Mumbai bench of the ITAT rules in favour of HSBC Bank

ITAT, Mumbai bench has ruled that interest income of Rs 1,498 crore earned by HSBC Bank during the Asst. Year 2015-16 from foreign currency loans and debt securities would not liable to tax in India. The tribunal dismissed the revenue department’s appeal in the case where the department wanted to tax the amount in India on the grounds that the interest income was not taxable under the India-Mauritius double taxation avoidance agreement (DTAA). The tribunal held that that interest received by the assessee, pursuant to Article 11(3)(c) of the India-Mauritius tax treaty would not be eligible to tax in India.

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