ITAT referred matter to larger bench to examine meanings of 'paid' appearing in Article 11 of India-Cyprus DTAA

INTERNATIONAL TAXATION : Matter referred to Larger Bench to examine connotations of expression 'paid' appearing in article 11 as in various decisions of Tribunal, there was no discussion about connotations of expression 'paid' and these decisions simply proceed on basis that since expression 'paid' is used in article 11(1) of India Cyprus tax treaty, taxability of interest can only be on cash basis

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