Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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Excess DDT paid on dividend distributed to a foreign parent was held refundable/adjustable by applying the beneficial DTAA rate. Since the shareholder was the beneficial owner and tax resident of the treaty partner jurisdiction, section 90(2) mandated application of Article 10 limiting tax on dividends to 10%, overriding the higher domestic rate charged under section 115-O. The plea that the return-filing utility did not permit claiming the treaty rate was accepted in principle, relying on the duty of the tax administration to facilitate compliance rather than defeat lawful claims through technical hurdles. The AO was directed to apply 10% and grant consequential relief. - ITAT
Excess DDT paid on dividend distributed to a foreign parent was held refundable/adjustable by applying the beneficial DTAA rate. Since the shareholder was the beneficial owner and tax resident of the treaty partner jurisdiction, section 90(2) mandated application of Article 10 limiting tax on dividends to 10%, overriding the higher domestic rate charged under section 115-O. The plea that the return-filing utility did not permit claiming the treaty rate was accepted in principle, relying on the duty of the tax administration to facilitate compliance rather than defeat lawful claims through technical hurdles. The AO was directed to apply 10% and grant consequential relief. - ITAT
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