2024 (1) TMI 944

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..... 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 Act') on 22/07/2020 for the Assessment Year 2....

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....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 Particulars Total (Rs.) Sennheiser Global Operations GMBH, Germ....

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....t 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 in section 115-O of the Act and not at the rate of tax applicable to the non-resident shareholders(s)....