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    <title>Treaty-rate relief for dividend distribution tax and MFN benefit recognised, with several TP disallowances deleted.</title>
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    <description>Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee&#039;s own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at .....</description>
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    <pubDate>Wed, 10 Jun 2026 07:26:55 +0530</pubDate>
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      <title>Treaty-rate relief for dividend distribution tax and MFN benefit recognised, with several TP disallowances deleted.</title>
      <link>https://www.taxtmi.com/highlights?id=100633</link>
      <description>Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee&#039;s own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at .....</description>
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