Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
