Guarantee commission’ not taxable as ‘other income’ under Article 22 of the India-Mauritius DTAA for a period prior to FY 2017–18 – Mumbai bench of the Tribunal
In brief
The Mumbai bench of the Income-tax Appellate Tribunal (Tribunal)1 has concluded that guarantee commission will not be taxable during financial year (FY) 2016–17 under Article 22 of the India-Mauritius Double Taxation Avoidance Agreement (DTAA), as sub-clause (3) of Article 22 of the DTAA came into effect only on 1 April 2017.
Sources
- ITA No. 603/Mum/2022
‘Guarantee commission’ not taxable as ‘other income’ under Article 22 of the India-Mauritius DTAA for a period prior to FY 2017–18 – Mumbai bench of the Tribunal
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