Payment of usance interest on deferred payment for purchase of assets from foreign suppliers : tax and commercial issues and a court ruling thereon

Comprehensive, scientific and truly international report about the Commissioner of Income Tax v. Vijay Ship Breaking Corporation before the Gujarat High Court. The case relates to the issue of withholding tax obligations (under the India-Singapore and India-UK income tax treaties) with regard to payments of interest to a non-resident for taking advantage of a deferred payment facility (usance credit). Key issues as to the treaty notion of "interest" are addressed.