Sale of Compulsorily Convertible Debentures Taxable Interest Income under the India–Mauritius Income Tax Treaty (1982)

This article analyses the recent ruling and the approach of the Indian Authority for Advance Rulings (AAR) in the case of Z regarding the India–Mauritius Income Tax Treaty (1982), and the AAR’s conclusion that the sale of compulsorily convertible debentures was interest income rather than capital gains.