https://www.taxtmi.com/caselaws?id=757897 ITAT Delhi ruled on AOP taxation where members' shares were determinate (domestic company 99.99%, foreign company 0.01%). The tribunal held that when AOP members have determinate shares and one member faces higher tax rates, the AOP's income should be taxed proportionally. Accordingly, 99.99% of AOP income was taxed at 30% (MMR) plus applicable surcharge and cess, while 0.01% was taxed at 40% plus surcharge and cess corresponding to the foreign company member's higher tax rate. Interest charges under sections 234A, 234B, and 234C were upheld. en-us Wed, 14 Aug 2024 00:00:00 +0530 Tue, 03 Sep 2024 15:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757897 ITAT Delhi ruled on AOP taxation where members' shares were determinate (domestic company 99.99%, foreign company 0.01%). The tribunal held that when AOP members have determinate shares and one member faces higher tax rates, the AOP's income should be taxed proportionally. Accordingly, 99.99% of AOP income was taxed at 30% (MMR) plus applicable surcharge and cess, while 0.01% was taxed at 40% plus surcharge and cess corresponding to the foreign company member's higher tax rate. Interest charges under sections 234A, 234B, and 234C were upheld. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757897