From this purchase regarding CIT(A), the Assessee as well as the Company filed attract in advance of the Tribunal
Held you to, when books out of membership off assessee aren’t prior to Area II and you can III of Plan VI so you’re able to Companies Operate, 1956, following AO was empowered to tinker having websites gain and then make enhancements u/s. 115JB to help you publication earnings.
S. 115-O: Residential businesses – Taxation with the marketed payouts – Relates question of beneficial treaty-speed more than DDT so you can Special Table
Assessee (Indian Co.) paid down dividend so you can the shareholders inside France and wanted to blow DDT during the all the way down price prescribed not as much as Asia-France DTAA by relying upon Delhi and you can Kolkata Counter rulings during the Giesecke & Devrient and you may Indian Petroleum Petronas. Continue reading “S. 115JB : Minimal solution taxation – disallowance u/s”