Two questions answered by the AAR as follows :

(1)    The interest earned by the applicant on non-convertible debentures of JKL Ltd is taxable at the rate of 15 per cent. as per article 11(2)(b) of the India-Singapore tax treaty.

(2)    JKL Ltd is liable to withhold tax at the rate of 15 % under the provision of section 195 of the Income-tax Act on payment of interest to applicant.