year against the dividend income
received from specified foreign companies u/s. 115BBD of the Act is neither
erroneous nor prejudicial to the interest ... taxing the foreign dividend income at
the specified rate as per section 115BBD of the Act inasmuch as in the absence of
any positive income
against foreign dividend income and upholding the levy of tax u/s 115BBD
of the Act on gross foreign dividend income. The interconnected second
issue ... earlier years against the foreign dividend income
referred to in section 115BBD of the Act, earned from investments which
are made with a view
assessee has
received dividend from specified foreign company as defined u/s
115BBD of Rs. 14,21,97,83,025/-. Ld. CIT further observed that ... provision of section 115BBD, the dividend amount
needed to be taxed separately @ 15% which was not done by AO
resulting in short levy
appellant and not allowing concessional rate of tax u/s. 115BBD of the
Act on the dividend received from Srilankan company when the same ... appellant and not allowing concessional rate of tax u/s. 115BBD of
the Act on the dividend received from Srilankan company when the
same
account of tax on dividend received from specified
foreign company u/s 115BBD of the Act without appreciating the fact that the
Company has rightly ... debts
ii) Tax on dividend received from specified foreign company under section
115BBD
iii) Deduction of festival and pooja expenses
iv) Deduction of GST paid
crores against the
income assessed u/s 115BBD of the Act should not be allowed and hence
income has escaped assessment."
6. In response ... pertaining to set-off of MAT credit
against tax computed u/s 115BBD amounting to Rs. 163.23 crores
and assessed the income
crores against the
income assessed u/s 115BBD of the Act should not be allowed and hence
income has escaped assessment."
6. In response ... pertaining to set-off of MAT credit
against tax computed u/s 115BBD amounting to Rs. 163.23 crores
and assessed the income
applied by appellant for calculating dividend
income chargeable to tax under Section
115BBD of the Act
Date on which foreign interim dividend ... total income of the assessee u/s
115BBD of the Act along with calculation of dividend distribution tax as
under:
"In view
Expenses disallowed Rs 27149018/-
Income from other sources u/s 115BBD Rs 272000000/-
4. Aggrieved the order of the AO the assessee company has
filed ... dividend of Rs 272000000/-this income was taxable
@15%u/s 115BBD of the Act without any deduction because
the assessee has reflected the income
which has been offered to tax u/s 115BBD of
the Act and hence question of Assessment order being erroneous and
prejudicial to the interest ... return of income as per the provisions of Section
115BBD of the Act. Section 115BBD of the Act refers to taxation of dividend
income received
