Assessee is  a Cyprus based company and was a wholly owned subsidiary of a company based in Mauritius. It invested in compulsorily convertible debentures (CCDs) of an Indian company and earned interest.  Assessee claimed benefit of tax rate of 10 per cent as per India-Cyprus DTAA.  Assessing Officer denied benefit of said rate on ground that Mauritius based company was beneficial owner of interest income and not assessee and taxed same at domestic rate of 40 per cent. Held that  investment in CCDs was done by assessee in its own name through proper banking channels and assessee had complete right to receive and enjoy interest income earned on CCDs without any obligation to pass on same to any other person.  Assessee had also got complete control over interest income on investment in CCDs and was free to enjoy same as per its own wish.  On facts, assessee being beneficial owner of interest income on CCDs from Indian entity, was entitled for taxability at a concessional rate as provided under article 11(2).  (AY. 2017-18)