whether the interest paid qualifies as penalty charges for late payment as per Article 11(6), whereby the exemption afforded by the said Article would stand excluded. If not, the exemption afforded by Article 11(1) would squarely apply and the interest paid by Ascendas to the assessee company in Netherlands owing to the sale of shares of VITP Ltd. would not be taxable in India.
whether the interest paid qualifies as penalty charges for late payment as per Article 11(6), whereby the exemption afforded by the said Article would stand excluded. If not, the exemption afforded by Article 11(1) would squarely apply and the interest paid by Ascendas to the assessee company in Netherlands owing to the sale of shares of VITP Ltd. would not be taxable in India.