Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
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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