https://www.taxtmi.com/caselaws?id=440725 The HC upheld the Tribunal's decision, allowing the respondent/assessee to claim a tax credit under the "tax sparing" provisions of Article 23 of the Indo-Thai DTAA. The court determined that the DTAA provisions, which include a deeming fiction for taxes exempted to promote economic development, take precedence over domestic laws. The HC found that the Thai statutory exemptions applied to the dividends received by the respondent/assessee's Thai subsidiary, rejecting the appellant/revenue's argument for remanding the issue for further examination. The appeals were dismissed, with no substantial question of law identified. en-us Tue, 18 Jul 2023 00:00:00 +0530 Wed, 25 Oct 2023 11:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440725 The HC upheld the Tribunal's decision, allowing the respondent/assessee to claim a tax credit under the "tax sparing" provisions of Article 23 of the Indo-Thai DTAA. The court determined that the DTAA provisions, which include a deeming fiction for taxes exempted to promote economic development, take precedence over domestic laws. The HC found that the Thai statutory exemptions applied to the dividends received by the respondent/assessee's Thai subsidiary, rejecting the appellant/revenue's argument for remanding the issue for further examination. The appeals were dismissed, with no substantial question of law identified. Case-Laws Income Tax Tue, 18 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440725