The Revenue sought to levy surcharge and education cess over and above the tax payable on interest under Article 11 of the India-Cyprus DTAA. The Tribunal held that the treaty specifically restricts tax on gross interest to 10 per cent and such ceiling includes the tax payable under the treaty. Accordingly, surcharge and education cess could not be levied over and above the treaty rate, and the Assessing Officer was directed to restrict the tax to 10 per cent of the gross interest. (AY. 2014-15)