(3)The provisions of this section shall not apply to—(a)interest paid in respect of a debt issued by a lender which is a permanent establishment in India of a non-resident engaged in the business of banking;(b)an Indian company or a permanent establishment of a foreign company which is engaged in the business of banking or insurance or a Finance Company located in any International Financial Services Centre, or such class of non-banking financial companies as may be notified by the Central Government in this behalf.