https://www.taxtmi.com/caselaws?id=449386 The Appellate Tribunal ITAT Delhi partially allowed the appellant's appeal for the assessment year 2021-22. The denial of a lower tax rate on dividend income under the India-Netherlands DTAA was upheld due to the absence of a specific notification for the MFN clause. The issue of charging tax at a higher rate than assessed was set aside for verification by the AO. The levy of interest under sections 234A and 234B was deemed consequential, requiring re-computation. Penalty proceedings under section 270A were dismissed as premature. The decision emphasized compliance with DTAA provisions and the necessity of specific notifications. en-us Thu, 08 Feb 2024 00:00:00 +0530 Sat, 10 Feb 2024 07:45:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449386 The Appellate Tribunal ITAT Delhi partially allowed the appellant's appeal for the assessment year 2021-22. The denial of a lower tax rate on dividend income under the India-Netherlands DTAA was upheld due to the absence of a specific notification for the MFN clause. The issue of charging tax at a higher rate than assessed was set aside for verification by the AO. The levy of interest under sections 234A and 234B was deemed consequential, requiring re-computation. Penalty proceedings under section 270A were dismissed as premature. The decision emphasized compliance with DTAA provisions and the necessity of specific notifications. Case-Laws Income Tax Thu, 08 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449386