Post by Aurtus Consulting LLP

The Chennai Tribunal, in a significant ruling, held that the provisions relating to limitation of interest deduction under Section 94B of the Income-tax Act, 1961 cannot be invoked since they result in discrimination prohibited under Article 24(4) of the India–Denmark DTAA solely based on the residence of the lender. Please refer to our alert summarizing key facts and observations of the ruling.   #Section94B #ThinCapitalization #InternationalTax #DTAA #NonDiscrimination #TransferPricing #Aurtus Vishal Gada | Rutul Shah | Zeel Jambuwala | Jay Parmar | Ritesh Kanodia | Meetika Baghel