PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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HC allowed the appeal, set aside the AAR ruling, and held that DDT is, in pith and substance, a tax on dividend income of the shareholder, though collected from the distributing company. Consequently, DDT falls within the scope of "tax on dividends" under Article 11 of the India-UK DTAA. By virtue of Section 90(2), the Appellant is entitled to apply the more beneficial treaty rate, limiting Indian tax on such dividends to 10%. Retention of DDT collected in excess of 10% is impermissible. The Department is, however, permitted to gross up the tax appropriately.
HC allowed the appeal, set aside the AAR ruling, and held that DDT is, in pith and substance, a tax on dividend income of the shareholder, though collected from the distributing company. Consequently, DDT falls within the scope of "tax on dividends" under Article 11 of the India-UK DTAA. By virtue of Section 90(2), the Appellant is entitled to apply the more beneficial treaty rate, limiting Indian tax on such dividends to 10%. Retention of DDT collected in excess of 10% is impermissible. The Department is, however, permitted to gross up the tax appropriately.
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