https://www.taxtmi.com/caselaws?id=408959 A cross-objection is treated as an appeal presented within time, so it may raise a new legal ground and is not confined more narrowly than an appeal. On the facts, the preliminary objections based on limitation and on the introduction of a new issue were rejected, and the cross-objection was held maintainable. On the treaty dividend article issue, the Tribunal noted conflicting views on whether dividend distribution tax falls within the treaty framework, considered the wider revenue and recurring importance of the question, and referred the matter to a Special Bench for authoritative determination. en-us Wed, 23 Jun 2021 00:00:00 +0530 Fri, 25 Jun 2021 07:13:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408959 A cross-objection is treated as an appeal presented within time, so it may raise a new legal ground and is not confined more narrowly than an appeal. On the facts, the preliminary objections based on limitation and on the introduction of a new issue were rejected, and the cross-objection was held maintainable. On the treaty dividend article issue, the Tribunal noted conflicting views on whether dividend distribution tax falls within the treaty framework, considered the wider revenue and recurring importance of the question, and referred the matter to a Special Bench for authoritative determination. Case-Laws Income Tax Wed, 23 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408959