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1 - 10 of 23 (1.63 seconds)Commissioner Of Income Tax - I vs Adani Wilmar Limited....Opponent(S) on 7 April, 2014
Section 195 in The Income Tax Act, 1961 [Entire Act]
Section 4 in The Income Tax Act, 1961 [Entire Act]
Section 5 in The Income Tax Act, 1961 [Entire Act]
Section 200A in The Income Tax Act, 1961 [Entire Act]
Section 90 in The Income Tax Act, 1961 [Entire Act]
Ranbaxy Laboratories Ltd., Delhi vs Dcit, New Delhi on 5 September, 2019
7.7 In the case of Uniphos Environtronic (P.) Ltd. v. DCIT [2017] 79
taxmann.com 75 (Ahmedabad - Trib.), the jurisdictional Ahmedabad
ITAT held that where tax had been deducted on fee for legal services to a
German company on strength of beneficial provisions of DTAA, provisions
of section 206AA could not be invoked because section 90(2) provides that
provisions of Act shall apply to the extent they are more beneficial to
assessee.
Jyoti Limited,, Vadodara vs Dcit,(International Taxation), , ... on 22 March, 2021
7.8 In the case of Jyoti Ltd. v. DCIT [2021] 127 taxmann.com 596
(Ahmedabad - Trib.), the Ahmedabad ITAT held that section 206AA does
not override provision of section 90 and, thus, TDS had been rightly
deducted by assessee on payment made to non-resident by applying tax rate
prescribed under DTAA and not as per section 206AA.