Dividend exclusion for nonresident companies applies where prescribed Indian dividend arrangements are not in place, limiting section 104. The amendment replaces sub-section (4) of section 104 to provide that section 104 shall not apply to a company which is neither an Indian company nor a company which has made the prescribed arrangements for the declaration and payment of dividends within India, while stating this is without prejudice to the provisions of section 108.
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Provisions expressly mentioned in the judgment/order text.
Dividend exclusion for nonresident companies applies where prescribed Indian dividend arrangements are not in place, limiting section 104.
The amendment replaces sub-section (4) of section 104 to provide that section 104 shall not apply to a company which is neither an Indian company nor a company which has made the prescribed arrangements for the declaration and payment of dividends within India, while stating this is without prejudice to the provisions of section 108.
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