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    <title>2024 (10) TMI 1654 - ITAT JAIPUR</title>
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    <description>ITAT Jaipur held that revision u/s 263 was not maintainable as AO&#039;s order was neither erroneous nor prejudicial to revenue. Regarding non-deduction of TDS on bank interest paid to foreign branches of Indian banks, Tribunal ruled that foreign branches of Indian banks are not non-residents under section 2(30) since control and management remains in India. Therefore, TDS under section 195 was not applicable. Additionally, section 194A(3)(iii)(f) exempts nationalized banks from TDS. On dividend income issue, Tribunal held that income from joint venture with 33.33% shareholding correctly treated as dividend u/s 115BBD, not business income, as assessee held more than prescribed 26% shares.</description>
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    <pubDate>Fri, 25 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (10) TMI 1654 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=461829</link>
      <description>ITAT Jaipur held that revision u/s 263 was not maintainable as AO&#039;s order was neither erroneous nor prejudicial to revenue. Regarding non-deduction of TDS on bank interest paid to foreign branches of Indian banks, Tribunal ruled that foreign branches of Indian banks are not non-residents under section 2(30) since control and management remains in India. Therefore, TDS under section 195 was not applicable. Additionally, section 194A(3)(iii)(f) exempts nationalized banks from TDS. On dividend income issue, Tribunal held that income from joint venture with 33.33% shareholding correctly treated as dividend u/s 115BBD, not business income, as assessee held more than prescribed 26% shares.</description>
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