Approval granted under s. 194LC(2)(ia) was based on a thorough evaluation of ECB agreement entered into between assessee and HSBC. Once such approval is granted, it logically follows that same agreement qualifies not just for concessional treatment under domestic law but also triggers beneficial treatment under DTAA, wherever applicable. Approval granted under S. 194LC(2)(ia) is substantive and sufficient for applying DTAA rate on interest payments to foreign lender. Foreign lender’s eligibility under DTAA having been established through supporting documentation, no further separate approval under S. 195(2) or S. 197 was required. Revenue directed to refund 5 per cent TDS amount deposited by assessee along with applicable interest under S. 244A.