Home » TaxBuzz » TaxBuzz | Interest paid on Capital Borrowed Outside India for Overseas Investment NOT exigible to tax in India – Assessee eligible for Refund of TDS: Delhi HC

DISCLAIMER: The material contained in this publication is solely for information and general guidance and not for advertising or soliciting. The information provided does not constitute professional advice that may be required before acting on any matter. While every care has been taken in the preparation of this publication to ensure its accuracy, Vaish Associates Advocates neither assumes responsibility for any errors, which despite all precautions, may be found herein nor accepts any liability, and disclaims all responsibility, for any kind of loss or damage arising on account of anyone acting / refraining to act by placing reliance upon the information contained in this publication.

We are pleased to share with you a copy of our in-house publication – “TaxBuzz”, wherein we have analysed the recent ruling of the Delhi High Court in the case of Sun Pharmaceuticals Industries Limited 2025:DHC:564-DB, wherein, the Hon’ble High Court has held that interest paid by an Indian Company on capital borrowed outside India for the purpose of overseas investment(s) in its subsidiaries, is not exigible to tax as the same is covered under the exclusions enumerated under section 9(1)(v)(b), thereby, not attracting TDS liability under section 195 of the Income Tax Act, 1961.

We trust that you will find our TaxBuzz useful and look forward to receiving your valuable feedback.

For any further information/ clarification, please feel free to write to:

Mr. Rohit Jain
Senior Partner
[email protected]

Mr. Aniket D. Agrawal
Associate Partner
[email protected]

Mr. Abhisek Singhvi
Associate
[email protected]

 

DOWNLOAD PDF FILE