Tribunal dismissed revenue’s appeal holding that withholding under section 195 of the Act is not required where annual interest on compulsorily convertible debentures was neither paid to the Cypriot investor by assessee and nor was it claimed as an expenditure. Tribunal also held that the purpose of deduction of tax at source is not to collect a sum which is not a tax levied under the Act, it is to facilitate the collection of tax lawfully leviable under the Act. The Tribunal regarding limitation under section 201 of the Act held that order made after the expiry of seven years from the end of the relevant financial year was not made within a reasonable time. (AY. 2011-12)