International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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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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