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Showing contexts for: TECHNIP in Technip India Ltd.,Noida vs Addl.Cit, Special Range- 9, New Delhi on 17 September, 2025Matching Fragments
6. In ITA No.6390/Del/2017 vide application dated 07.02.2020, additional ground of appeal under Rule 11 of the Income Tax (Appellate Tribunal) Rules, 1963 was taken, as under:
"1. On the facts and circumstances of the case and in law, the assessing officer/Commissioner of Income-tax (Appeals) ought to have restricted the levy of the dividend distribution tax, on the dividend distributed to Technip France SA (formerly known as Technip France SAS), to beneficial tax rate in accordance with Article 11 of the double taxation avoidance agreement (DTAA) between India and France read with para 7 of the protocol thereto, instead of 16.995% charged in terms of section 115-O of the Income-Tax Act, 1961."