Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
The ITAT held that where a domestic company declares, distributes, or pays dividends to non-resident shareholders, attracting Additional Income-tax (Tax on Distributed Profits) u/s 115-O of the Act, such additional income tax payable by the domestic company shall be at the rate mentioned in Section 115-O and not at the rate applicable to the non-resident shareholders as per the relevant DTAA. The ITAT was conscious of the sovereign's prerogative to extend treaty protection to domestic companies paying dividend distribution tax through DTAAs. However, the domestic company can claim the benefit of the DTAA only if the Contracting States intend to extend such treaty protection. The decision was against the assessee.
The ITAT held that where a domestic company declares, distributes, or pays dividends to non-resident shareholders, attracting Additional Income-tax (Tax on Distributed Profits) u/s 115-O of the Act, such additional income tax payable by the domestic company shall be at the rate mentioned in Section 115-O and not at the rate applicable to the non-resident shareholders as per the relevant DTAA. The ITAT was conscious of the sovereign's prerogative to extend treaty protection to domestic companies paying dividend distribution tax through DTAAs. However, the domestic company can claim the benefit of the DTAA only if the Contracting States intend to extend such treaty protection. The decision was against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
