Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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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