Abstract
This case note sets out the ruling by the Authority for Advance Rulings in Societe De Promotion Et De Participation Pour La Cooperation Economique that an appraisal front-end fee charged by the taxpayer to its client borrowers was not taxable in India as interest because it was not linked to the loan and not payable if the loan was not approved. However, all other fees (i.e. non-appraisal front-end fees, commitment fees, cancellation fees, monitoring fees and amendment fees) were taxable in India as interest income in terms of article 12(4) of the France-India Income and Capital Tax Treaty (1992) because they were payable only after the debt claim came into existence.
Sign-in/Register to access full text options 
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Schedule a callDisclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.
