Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Dividend Distribution Tax on dividends paid to Swiss tax resident shareholders was held to be restricted to the more beneficial rate under Article 10 of the India-Switzerland DTAA, following the jurisdictional High Court decision in Colorcon Asia and the rejection of the earlier Special Bench view in Total Oil India. The Tribunal accepted that the treaty rate governed the levy and rejected the Department's beneficial ownership objection because no doubt had been recorded by the assessing or appellate authorities. DDT was therefore to be recomputed at 10%, with refund of excess tax paid.
Dividend Distribution Tax on dividends paid to Swiss tax resident shareholders was held to be restricted to the more beneficial rate under Article 10 of the India-Switzerland DTAA, following the jurisdictional High Court decision in Colorcon Asia and the rejection of the earlier Special Bench view in Total Oil India. The Tribunal accepted that the treaty rate governed the levy and rejected the Department's beneficial ownership objection because no doubt had been recorded by the assessing or appellate authorities. DDT was therefore to be recomputed at 10%, with refund of excess tax paid.
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