2024 (1) TMI 944

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....h. Sanjay Kumar, Sr. DR ORDER PER M. BALAGANESH, AM: This appeal of the Assessee arises out of the order of the CIT(A), National Faceless Appeal Centre, Delhi, [hereinafter referred to as ['NFAC'] in Appeal No.CIT(A),Gurgaon- 1/10181/2020-21, dated 22/07/2020 against the order passed by Central Processing Unit, Bengaluru u/s 143(1) of the Income Tax Act (hereinafter referred to as 'the Ac....

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.... on 09.03.2020 declaring total income of Rs. 3,77,00,470/-. 5. During the year under consideration the assessee distributed dividends to its share holders (Senniheiser Global Operations GMBH, Germany and Sennheiser Electronic GMBH & Co. KG, Germany) and paid DDT on distribution of dividends under section 115-O of the Act as under:-     Dividends to share holders Particular....

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....taxmann.com 332 wherein it was held as under :- "83. For the reasons give above, we hold that where dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s), which attracts Additional Income-tax (Tax on Distributed Profits) referred to in sec.115-O of the Act, such additional income tax payable by the domestic company shall be at the rate mentioned ....