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DDT

Special Rate ProvisionsSection 115-OSection 115-O499 judgments

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1779/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-2012

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case, the Ld. CIT(A) erred\nin following ... Court in\ncase of Tata Tea Co. Ltd (398 ITR 260) (SC) upholding that the said\ndecision has not dealt with the nature of DDT i.e. as to whether it\nis a tax on the company or a shareholder.\n2. 2. That on the facts and circumstances of the case

PHILIPS INDIA LTD.,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1778/KOL/2024[2010-2011]Status: DisposedITAT Kolkata20 Mar 2026AY 2010-2011

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Npage | 2\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case, the Ld. CIT(A) erred\nin following ... Court in\ncase of Tata Tea Co. Ltd (398 ITR 260) (SC) upholding that the said\ndecision has not dealt with the nature of DDT i.e. as to whether it\nis a tax on the company or a shareholder.\n2. 2. That on the facts and circumstances of the case

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1776/KOL/2024[2008-2009]Status: DisposedITAT Kolkata20 Mar 2026AY 2008-2009

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case, the Ld. CIT(A) erred\nin following ... Court in\ncase of Tata Tea Co. Ltd (398 ITR 260) (SC) upholding that the said\ndecision has not dealt with the nature of DDT i.e. as to whether it\nis a tax on the company or a shareholder.\n2. 2. That on the facts and circumstances of the case

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that the claim of deduction u/s 80G amounting to Rs. 92,31,072/- be allowed. GROUND NO. V: NON-GRANTING OF DIVIDEND DISTRIBUTION TAX (“DDT”) AMOUNTING TO RS. 10,17,96,378/- 1. On the facts and circumstances of case and in law, CIT(A) erred in upholding the action ... distribution tax paid by the Appellant amounting to Rs. 10,17,96,378/- in the computation sheet and in not granting refund of excess DDT paid amounting to Rs. 81,10,486/-. 2. The Appellant prays that the AO be directed to grant the full credit of DDT amounting

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