Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
Page of 4809
Press 'Enter' after typing page number.
3261 to 3280 of 96177 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
