Tax scope: dividends and cross-border royalty/FTS redefined to exclude certain section-specific incomes under amended provisions. Amendment revises clause (a) to treat 'dividends other than dividends referred to in section 115-O' as the operative category of dividends, and revises clause (b) to define 'a non-resident (not being a company) or a foreign company' as including income by way of royalty or fees for technical services, while excluding income referred to in sub section (1) of section 44DA.
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Provisions expressly mentioned in the judgment/order text.
Tax scope: dividends and cross-border royalty/FTS redefined to exclude certain section-specific incomes under amended provisions.
Amendment revises clause (a) to treat "dividends other than dividends referred to in section 115-O" as the operative category of dividends, and revises clause (b) to define "a non-resident (not being a company) or a foreign company" as including income by way of royalty or fees for technical services, while excluding income referred to in sub section (1) of section 44DA.
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