Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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