Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Taxability of dividends - dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s) - The Tribunal held that, additional income tax payable by the domestic company shall be at the rate mentioned in Section 115- O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. - Claim of refund of excess Dividend Distribution Tax (DDT) rejected.
Taxability of dividends - dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s) - The Tribunal held that, additional income tax payable by the domestic company shall be at the rate mentioned in Section 115- O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. - Claim of refund of excess Dividend Distribution Tax (DDT) rejected.
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