Residential status and type of income
This query is : Resolved
Querist : Anonymous
Querist :
Anonymous
(Querist)
16 August 2012
Case 1 : A(NR)gives loan to B(R). He invests it in shares in India. Interst income of A is accruring/arising in India.
Case 2: C(NR)gives loan to D(NR). He invests in shares in India. Interest income of C is accruring/arising abroad.
Whats the difference b/w the 2 cases?
Case 2: C(NR)gives loan to D(NR). He invests in shares in India. Interest income of C is accruring/arising abroad.
Whats the difference b/w the 2 cases?
Amol S Joglekar
(Expert)
16 August 2012
CASE 1: The loan agreement will decide the taxability. Loan given for specific purpose of investing in shares in Indian companies shall definitely attract Indian Tax on the interest earned. CASE2: subject to VODAFONE case stand, this will accrue out of India... Again the purpose of loan shall play a deciding role. In normal case of LOAN, it will accrue out of India.
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