Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
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