Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
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