Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
Dividend distribution tax paid on dividends to non-resident shareholders is treated as tax on the shareholder's dividend income, so the more beneficial DTAA rate prevails over domestic law where applicable. The text notes that, following the Bombay High Court view in Colorcon Asia Pvt. Ltd., the assessee's claim for treaty-rate taxation of dividends paid to UK and Netherlands shareholders was accepted in principle. The matter was remitted only to determine the correct treaty rate under the relevant articles and to compute and refund any excess DDT.
Dividend distribution tax paid on dividends to non-resident shareholders is treated as tax on the shareholder's dividend income, so the more beneficial DTAA rate prevails over domestic law where applicable. The text notes that, following the Bombay High Court view in Colorcon Asia Pvt. Ltd., the assessee's claim for treaty-rate taxation of dividends paid to UK and Netherlands shareholders was accepted in principle. The matter was remitted only to determine the correct treaty rate under the relevant articles and to compute and refund any excess DDT.
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