https://www.taxtmi.com/caselaws?id=407273 ITAT held that the assessee's activity of blending butane and propane using sophisticated plant and machinery results in manufacture/production of a distinct commercial product, LPG, within the meaning of section 2(29BA. Consequently, the assessee is eligible for additional depreciation under section 32(1)(iia), and the Revenue's appeal on this issue was dismissed. On the issue of tax on dividend distributed to non-resident shareholders, ITAT held that section 195A was inapplicable since the tax incidence arises by statute, and the applicable tax rate must be determined under the relevant DTAA article, if more beneficial. Accepting the assessee's additional ground, ITAT remanded this issue to the AO for fresh adjudication in accordance with law. en-us Fri, 30 Apr 2021 00:00:00 +0530 Tue, 09 Dec 2025 11:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407273 ITAT held that the assessee's activity of blending butane and propane using sophisticated plant and machinery results in manufacture/production of a distinct commercial product, LPG, within the meaning of section 2(29BA. Consequently, the assessee is eligible for additional depreciation under section 32(1)(iia), and the Revenue's appeal on this issue was dismissed. On the issue of tax on dividend distributed to non-resident shareholders, ITAT held that section 195A was inapplicable since the tax incidence arises by statute, and the applicable tax rate must be determined under the relevant DTAA article, if more beneficial. Accepting the assessee's additional ground, ITAT remanded this issue to the AO for fresh adjudication in accordance with law. Case-Laws Income Tax Fri, 30 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407273