Search Results for "Double Taxation Avoidance Agreement"

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Bombay High Court Dismisses Assessee's Appeal in Income Tax Case on Dividend Distribution Tax Rate. DDT under Section 115-O is a tax on the company, not on shareholders, and the India-UK DTAA does not provide a lower rate for DDT.

The Bombay High Court dismissed a batch of seven appeals filed by Foseco India Ltd. under Section 260A of the Income Tax Act, 1961, challenging a comm...

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Supreme Court Dismisses Department's Appeal in Permanent Establishment Tax Dispute Under India-Korea DTAA. Court Upholds ITAT's Finding of Permanent Establishment but Remands Profit Attribution for Fresh Assessment Due to Insufficient Material.

The dispute arose from the taxability of income attributable to a permanent establishment set up in India by Samsung Heavy Industries Co. Ltd., a Sout...

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High Court Dismisses Writ Petition in Income Tax Matter Involving India-China DTAA Interpretation. Petitioner's Claim for NIL Withholding Tax Certificate Rejected Due to Pending Assessments and Previous Tax Determinations Under Section 197 of Income Tax Act, 1961.

The dispute involved a Chinese company, Petitioner, which provided technical services to its Indian subsidiary, Benteler India Private Limited, under ...

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Madras High Court Dismisses Revenue's Appeal in Penalty Case for Wrongful DTAA Claim — No Concealment Found. Assessee's Bonafide Belief That India-China DTAA Applied to Hong Kong Based on Official Document Precludes Penalty Under Section 271(1)(c) of Income Tax Act, 1961.

The revenue appealed against the common order of the Income Tax Appellate Tribunal (ITAT) which set aside the levy of penalty under Section 271(1)(c) ...

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Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income Tax Act, 1961 for Non-Resident Company — Lack of Reasonable Belief of Income Escaping Assessment. Reassessment Based on Mere Change of Opinion is Impermissible; Notice and Order Rejecting Objections Set Aside.

The petitioner, Indivest Pte Ltd, a company incorporated in Singapore and wholly owned by the Government of Singapore, filed a writ petition challengi...