Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
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Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed.
Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed.
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