https://www.taxtmi.com/caselaws?id=755828 Prior coordinate bench decisions in the assessee's own case were followed on demurrage charges and reimbursement of salary to seconded employees, with the Tribunal accepting that no tax deduction at source was required on those facts and that the related disallowances under section 40(a)(ia) could not stand. On the dividend distribution tax issue, the Tribunal applied the Special Bench view and later Supreme Court authority to hold that treaty protection under the India-France treaty and Most Favoured Nation clause does not override dividend distribution tax under section 115-O unless the treaty expressly so provides; the claim for refund or credit of excess DDT was rejected. en-us Fri, 03 Nov 2023 00:00:00 +0530 Fri, 19 Jul 2024 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755828 Prior coordinate bench decisions in the assessee's own case were followed on demurrage charges and reimbursement of salary to seconded employees, with the Tribunal accepting that no tax deduction at source was required on those facts and that the related disallowances under section 40(a)(ia) could not stand. On the dividend distribution tax issue, the Tribunal applied the Special Bench view and later Supreme Court authority to hold that treaty protection under the India-France treaty and Most Favoured Nation clause does not override dividend distribution tax under section 115-O unless the treaty expressly so provides; the claim for refund or credit of excess DDT was rejected. Case-Laws Income Tax Fri, 03 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755828