Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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