https://www.taxtmi.com/highlights?id=74156 Revision u/s 264 - Claiming benefit of DTAA - refund of Dividend Distribution Tax (DDT) which was paid wrongly - This was not a case where a deduction was made u/s 195 towards tax on payments made to a non-resident and the parties had agreed that the deducting resident entity would bear the tax liability by compensating the non-resident by a proportional top up. Therefore, Section 248 is clearly inapplicable. The second ground on which the revision petition was rejected is also consequently unsustainable. - Pr.CIT directed to reconsider the matter u/s 264 - HC en-us Sat, 13 Jan 2024 18:32:49 +0530 Sat, 13 Jan 2024 18:32:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74156 Revision u/s 264 - Claiming benefit of DTAA - refund of Dividend Distribution Tax (DDT) which was paid wrongly - This was not a case where a deduction was made u/s 195 towards tax on payments made to a non-resident and the parties had agreed that the deducting resident entity would bear the tax liability by compensating the non-resident by a proportional top up. Therefore, Section 248 is clearly inapplicable. The second ground on which the revision petition was rejected is also consequently unsustainable. - Pr.CIT directed to reconsider the matter u/s 264 - HC Highlights Income Tax Sat, 13 Jan 2024 18:32:49 +0530 https://www.taxtmi.com/highlights?id=74156