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“DDT”

Special Rate ProvisionsSection 115-OSection 115-O499 judgments

The decision most relied on for DDT is Sesa Goa Ltd. v. JCIT (117 Taxmann.com 96), cited in 291 judgments on BharatTax.

Leading authorities on DDT

Sesa Goa Ltd. v. JCIT
117 Taxmann.com 96 · 2020 · High Court
291
citing judgments

Education cess paid on total income and dividend distribution tax are allowable deductions for income tax purposes.

Trib.) Giesecke & Devrient 16.994%). India Pvt Ltd. v. ACIT
120 Taxmann.com 338 · 2020 · High Court
52
citing judgments

The provisions of a Double Taxation Avoidance Agreement (DTAA) would prevail over the domestic law rate of Dividend Distribution Tax (DDT) under Section 115-O.

Union of India v. Tata Tea Co Ltd.
398 ITR 260 · 2017 · Supreme Court
38
citing judgments

Dividend Distribution Tax (DDT) is a tax on the profits of the domestic company, not on the shareholder. The Supreme Court's decision in Tata Tea Co. Ltd. did not address the precise nature of DDT as a tax on the company versus the shareholder.

Torrent India Pvt. Ltd. v. CIT
35 Taxmann.com 300 · 2013 · High Court
36
citing judgments

Excess Dividend Distribution Tax (DDT) paid by a company is refundable to the assessee, even though Section 115-O(4) states DDT is a final payment.

SIDBI v. CBDT
133 Taxmann.com 158 · 2021 · High Court
23
citing judgments

Dividend Distribution Tax (DDT) under section 115-O is a charge on the company's profits and not on the income in the hands of the shareholder, meaning it does not constitute double taxation and is not subject to Double Taxation Avoidance Agreements (DTAA).

Genpact India (P). Ltd. v. Dy. CIT
111 Taxmann.com 402 · 2019 · Supreme Court
11
citing judgments

An assessee can challenge tax liability arising from special charging provisions, such as Section 115QA, by filing a separate appeal under Section 246A. Dividend Distribution Tax (DDT), as an additional tax not linked to the computation of total income, must be appealed independently.

AMD Metplast (P.) Ltd. v. Dy. CIT
20 Taxmann.com 647 · 2012 · High Court
10
citing judgments

Commission paid to a Managing Director for services rendered is eligible for deduction under section 36(1)(ii) of the Income-tax Act, 1961, provided it is paid as per the terms of employment and not merely to avoid Dividend Distribution Tax (DDT).

Judgments citing DDT

Lord India P.Ltd, Mumbai vs. Asst CIT 10(2)(1), Mumbai

In the result we allow the additional ground raised by the assessee and quash the assessment order

ITA 424/MUM/2016[2011-12]Status: DisposedITAT Mumbai24 Apr 2023AY 2011-12

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhaillord India Private Vs. Assistant Commissioner Limited (F Ormer Ly Know N A S L Ord Of Income-Tax, Circle- India C Hem Ica L Pr Od Uct S Pv T. Lt D. ) 10(2)(1), Room No. 509, A/401-404, 215 – Atrium Aayakar Bhavan, Chakala, Andheri – Kurla M.K. Road, Road Andheri (East) Mumbai - 400020 Mumbai - 400093 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0785H Appellant .. Respondent Appellant By : M.P. Lohia Respondent By : Dr. Samual Pitta Date Of Hearing 29.03.2023 Date Of Pronouncement 24.04.2023 आदेश / O R D E R Per Amarjit Singh (Am): The Present Appeal Filed By The Assesse Is Directed Against The Order Passed By The Drp-1, Mumbai Dated 26.02.2015 For A.Y. 2011- 12. The Assesse Has Raised The Following Grounds Before Us: “1. Transfer Pricing - Availing Of Intra-Group Services 1.1 On The Facts & Circumstances Of The Case & In Law, The Learned Acit/ Drp Erred In Determining The Arm'S Length Price In Relation To The International Transaction Relating To The Availing Of Group Benefit Services/ Technical Service Management Services (Hereinafter Referred To As "Intra-Group Services") Of Rs.1,14,87,092 To Be Rs. 22,97,418/-, Thus Making An Adjustment Of Rs.91,89,674/- & Thereby Disregarding The Fact That The Appellant Had Received The Services For The Purposes Of Its Business. In Doing So, The Learned Acit/ Drp Grossly Erred By Not Appreciating The Commercial Wisdom/ Expediency Of The Appellant

For Appellant: M.P. LohiaFor Respondent: Dr. Samual Pitta
Section 40

learned ACIT/ DRP erred in not considering the submissions of the appellant in the correct perspective. 4. Incorrect computation of Dividend Distribution tax (DDT) and related interest and credit for DDT paid not granted P a g e | 4 Lord India Pvt. Ltd. vs. ACIT, Circle ... learned ACIT erred in computing the total DDT and interest payable by the appellant at Rs.1,48,25,035/- as against at the correct amount of Rs.1,43,41,550/-. 4.2 The learned ACIT erred in not granting credit for DDT of Rs.37,17,656/- paid by the appellant

Maruti Suzuki India Ltd, New Delhi vs. DCIT, Circle-16(1), New Delhi

ITA 1953/DEL/2022[2018-19]Status: FixedITAT Delhi20 Apr 2023AY 2018-19

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

For Appellant: Shri Niraj ShethFor Respondent: Shri Vinod Tanwani, CIT-DR
Section 115

shareholders resident in those DTAA countries cannot exceed 10%. The DDT tax rate is 15% + grossing up u/s.115O and this is the reason, perhaps, why domestic company paying DDT to Non-Resident shareholders claim that the rate of DDT in such cases has to be only at 10% based ... payable by the shareholder, whose liability is discharged by the domestic company in the form of payment of DDT? The nature of DDT first came for consideration before the Hon’ble Calcutta High Court in the case of Jayshree Tea and Industries Ltd. v. Union of India, (supra

Maruti Suzuki India Ltd, New Delhi vs. DCIT, Circle-16(1), New Delhi

ITA 1952/DEL/2022[2017-18]Status: FixedITAT Delhi20 Apr 2023AY 2017-18

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

For Appellant: Shri Niraj ShethFor Respondent: Shri Vinod Tanwani, CIT-DR
Section 115

shareholders resident in those DTAA countries cannot exceed 10%. The DDT tax rate is 15% + grossing up u/s.115O and this is the reason, perhaps, why domestic company paying DDT to Non-Resident shareholders claim that the rate of DDT in such cases has to be only at 10% based ... payable by the shareholder, whose liability is discharged by the domestic company in the form of payment of DDT? The nature of DDT first came for consideration before the Hon’ble Calcutta High Court in the case of Jayshree Tea and Industries Ltd. v. Union of India, (supra

Maruti Suzuki India Ltd., New Delhi vs. DCIT, Circle-16(1), New Delhi

ITA 521/DEL/2021[2016-17]Status: FixedITAT Delhi20 Apr 2023AY 2016-17

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

For Appellant: Shri Niraj ShethFor Respondent: Shri Vinod Tanwani, CIT-DR
Section 115

shareholders resident in those DTAA countries cannot exceed 10%. The DDT tax rate is 15% + grossing up u/s.115O and this is the reason, perhaps, why domestic company paying DDT to Non-Resident shareholders claim that the rate of DDT in such cases has to be only at 10% based ... payable by the shareholder, whose liability is discharged by the domestic company in the form of payment of DDT? The nature of DDT first came for consideration before the Hon’ble Calcutta High Court in the case of Jayshree Tea and Industries Ltd. v. Union of India, (supra

Maruti Suzuki India Limited, New Delhi vs. ACIT, Spl. Range-6, New Delhi

ITA 8968/DEL/2019[2015-16]Status: HeardITAT Delhi20 Apr 2023AY 2015-16

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

For Appellant: Shri Niraj ShethFor Respondent: Shri Vinod Tanwani, CIT-DR
Section 115

shareholders resident in those DTAA countries cannot exceed 10%. The DDT tax rate is 15% + grossing up u/s.115O and this is the reason, perhaps, why domestic company paying DDT to Non-Resident shareholders claim that the rate of DDT in such cases has to be only at 10% based ... payable by the shareholder, whose liability is discharged by the domestic company in the form of payment of DDT? The nature of DDT first came for consideration before the Hon’ble Calcutta High Court in the case of Jayshree Tea and Industries Ltd. v. Union of India, (supra

Maruti Suzuki India Ltd., New Delhi vs. DCIT, Circle-16(1), New Delhi

ITA 8009/DEL/2018[2014-15]Status: HeardITAT Delhi20 Apr 2023AY 2014-15

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

For Appellant: Shri Niraj ShethFor Respondent: Shri Vinod Tanwani, CIT-DR
Section 115

shareholders resident in those DTAA countries cannot exceed 10%. The DDT tax rate is 15% + grossing up u/s.115O and this is the reason, perhaps, why domestic company paying DDT to Non-Resident shareholders claim that the rate of DDT in such cases has to be only at 10% based ... payable by the shareholder, whose liability is discharged by the domestic company in the form of payment of DDT? The nature of DDT first came for consideration before the Hon’ble Calcutta High Court in the case of Jayshree Tea and Industries Ltd. v. Union of India, (supra

Hersh Washesher Chadha, New Delhi vs. ACIT Circle (International Taxation) - 1(2)(1), New Delhi

In the result, the appeal is allowed, as indicated above

ITA 123/DEL/2021[2017-18]Status: DisposedITAT Delhi13 Apr 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18

Section 133(6)Section 69A

return of income filed in India for assessment year 2016-17 and also from the fact that the company distributing the dividend has paid DDT. Thus, it is very much clear, the assessee has established not only the source of fund in the NRO account in India but the source

Dcm Shriram Industries Limited, New Delhi vs. ACIT, Circle-7(1), Delhi

In the result, the appeals are partly allowed

ITA 1000/DEL/2022[2017-18]Status: DisposedITAT Delhi15 Mar 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

wrongly charging interest under said section. 4.5 That the Id. AO has erred in raising an incorrect demand on account of DDT payable [Rs.1,06,25,713/-] and interest u/s 115P [Rs.71,19,228/-] completely ignoring that DDT amounting to Rs.1,06,25,713/- has been duly paid

Dcm Shriram Industries Ltd, New Delhi vs. Addi. CIT National E - Assesment Centre, New Delhi

In the result, the appeals are partly allowed

ITA 539/DEL/2021[2016-17]Status: DisposedITAT Delhi15 Mar 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

wrongly charging interest under said section. 4.5 That the Id. AO has erred in raising an incorrect demand on account of DDT payable [Rs.1,06,25,713/-] and interest u/s 115P [Rs.71,19,228/-] completely ignoring that DDT amounting to Rs.1,06,25,713/- has been duly paid

Dcm Shriram Industries Ltd, New Delhi vs. Addi. CIT Special Range-3, New Delhi

In the result, the appeals are partly allowed

ITA 1841/DEL/2020[2015-16]Status: DisposedITAT Delhi15 Mar 2023AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

wrongly charging interest under said section. 4.5 That the Id. AO has erred in raising an incorrect demand on account of DDT payable [Rs.1,06,25,713/-] and interest u/s 115P [Rs.71,19,228/-] completely ignoring that DDT amounting to Rs.1,06,25,713/- has been duly paid

Vedanta Ltd (Formerly Known As Sesa Sterlite Ltd.), New Delhi vs. ACIT, Circle- 26(1), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5367/DEL/2019[2013-14]Status: DisposedITAT Delhi02 Feb 2023AY 2013-14

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2013-14 Vedanta Ltd. (Formerly Vs. Acit, Known As Sesa Sterlite Ltd.) Circle-26(I) Core-6, 3Rd Floor, New Delhi. Scope Complex, 7, Lodhi Road, New Delhi – 110 003 Pan Aaccs7101B (Appellant) (Respondent)

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Shri T. Kipgen, CIT DR
Section 115Section 237

rejecting the claim of Appellant seeking refund of Rs. 11,22,14,052, being excess Dividend Distribution Tax (referred to as “DDT”), allegedly on the ground that there is no provision under the Income Tax Act, 1961 (‘the Act’) to allow granting such refund of DDT. Vedanta Ltd. vs. ACIT ... which was later on merged with the Appellant. 1.2 That the CIT(Appeals) erred on facts and in law in not appreciating that the DDT being an additional income tax paid by the Appellant, the refund of the same could be claimed under Section 237 of the Act. 1.3 That

ACIT, Circle-12(1), New Delhi vs. Icra Limited, New Delhi

ITA 9199/DEL/2019[2016-17]Status: DisposedITAT Delhi10 Jan 2023AY 2016-17

Bench: Sh. Pradip Kumar Kedia & Sh. Anubhav Sharmaacit, Vs. M/S. Icra Limited 1105, 11Th Floor, Circle-12(1), New Delhi Kailash Building 26, Kasturba Gandhi Marg, Connaught Place, New Delhi-110001 Pan : Aaacg7758B Appellant Respondent

Section 143(3)Section 14A

circumstances of the case and in law, Education Cess (“EC”) and Secondary Higher Education Cess (“SHEC”) paid on Income Tax and Dividend Distribution Tax (“DDT”) needs to be considered as an allowable expenditure under section 37(1) of the Act. The appellant craves leaves to add, amend, alter, delete, rescind

Wns Global Services P. Ltd., Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, Nationa Faceless Assessment Centre, Dilhi

In the result, appeal filed by the assessee is allowed

ITA 1259/MUM/2021[2016-17]Status: DisposedITAT Mumbai09 Dec 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyalwns Global Services Pvt. Ltd., Pl 10, Gate No.4, Godrej & Boyce Complex, Pirojshanagar, Lbs Marg, Vikhroli (West), Mumbai-400079. Pan: Aaacw2598L ...... Appellant Vs.. Addl./Jt/Dy./Acit/Ito/Nfac, Room No. 455, Circle-14(3)(1), Mumbai. ..... Respondent Appellant/Assessee By : Sh. Porus Kaka, Sr. Adv. & Sh. Manish Kant Respondent/Revenue By : Sh. Jasdeep Singh, Cit-Dr

For Appellant: Sh. Porus Kaka, Sr. Adv. &For Respondent: Sh. Jasdeep Singh, CIT-DR
Section 143(3)Section 144C(13)Section 92B

applicable to the facts of the present case as Section 115-0(5) of the Act is about deduction of dividend and DDT thereon and not about deductibility of expenses in relation of earning exempt income. Incorrect computation under Rule 8D of the Rules (d) Incorrect computation under Rule

Dy CIT CC-1(4), Mumbai vs. M/S Grasim Industries Ltd., Mumbai

ITA 41/MUM/2021[2018-19]Status: DisposedITAT Mumbai30 Nov 2022AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri. J.D Mistry, Sr. AdvFor Respondent: Shri Anil Singh
Section 115OSection 115QSection 2

failed to appreciate that if at all deemed dividend is to be computed u/s 2(22)(a) of the Act, then the liability of DDT payable in respect of Appellant's non-resident shareholders is to be computed having regard to provisions of the respective Double Taxation Avoidance Agreement ... Appellant submits that the valuation adopted by the Id. CIT(A) for computing the amount of DDT is not sustainable in law. GROUND NO. 6. ORDERS PASSED BY THE AO AND THE CIT(A) CONTRARY TO THE PRINCIPAL OF NATURAL JUSTICE: 6.1 On the facts and in the circumstances

Grasim Industries Ltd., Mumbai vs. Dy CIT, Central Circle-1(4), Mumbai

ITA 1935/MUM/2020[2018-19]Status: DisposedITAT Mumbai30 Nov 2022AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri. J.D Mistry, Sr. AdvFor Respondent: Shri Anil Singh
Section 115OSection 115QSection 2

failed to appreciate that if at all deemed dividend is to be computed u/s 2(22)(a) of the Act, then the liability of DDT payable in respect of Appellant's non-resident shareholders is to be computed having regard to provisions of the respective Double Taxation Avoidance Agreement ... Appellant submits that the valuation adopted by the Id. CIT(A) for computing the amount of DDT is not sustainable in law. GROUND NO. 6. ORDERS PASSED BY THE AO AND THE CIT(A) CONTRARY TO THE PRINCIPAL OF NATURAL JUSTICE: 6.1 On the facts and in the circumstances

Astrazeneca Pharma India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 460/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

961/DEU2014), has held that tax rates specified in Double Taxation Avoidance Agreement ("DTAA") in respect of dividend must prevail over dividend distribution tax ("DDT"). In light of the above judicial development, the Appellant wishes to file an additional legal ground of appeal (enclosed as Annexure 1) for claiming refund

DCIT, Bangalore vs. M/S Astra Zenca Pharma India Ltd., Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 446/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

961/DEU2014), has held that tax rates specified in Double Taxation Avoidance Agreement ("DTAA") in respect of dividend must prevail over dividend distribution tax ("DDT"). In light of the above judicial development, the Appellant wishes to file an additional legal ground of appeal (enclosed as Annexure 1) for claiming refund

M/S United Spirits Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-7, Bangalore

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR
Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

appeal relating to disallowance Rs.3,56,55,510 on / adjustments pursuant to findings of the disallowance project spirit report. Rs.28,06,21,440 on DDT and interest of Rs.15,43,41,791 u/s 115P of the Act. 8. Grounds of appeal relating to short credit

Dr. L.S. Ravi Prakash, Bangalore vs. Deputy Commissioner of Income Tax, Circle-5(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 30/BANG/2021[2011-12]Status: DisposedITAT Bangalore28 Oct 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2011-12

For Appellant: Shri G. Sathyanarayana, A.RFor Respondent: Shri Praveen Karanth, D.R
Section 78

support of its claim. The purpose behind the introduction of section 2(22)(e) was to curb the avoidance of Dividend Distribution Tax (DDT) u/s 115-0 by changing the colour of the dividend payouts under the garb of advances, unsecured loans etc. Therefore, the AO is right in bringing

Life Insurance Corporation of India, Mumbai vs. Dy.Commissioner of Income Tax-3(2)(1), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1714/MUM/2022[2013-14]Status: DisposedITAT Mumbai29 Sept 2022AY 2013-14

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blelife Insurance Corporation Of India V. Dcit – 3(2)(1) Central Office, F&A Department Room No. 608 3Rd Floor, West Wing Aayakar Bhavan, M.K. Road “Yogakshema” Jeevan Bima Marg Mumbai - 400020 Mumbai - 400021 Pan: Aaacl0582H Appellant Respondent Acit – 3(2)(1) V. M/S. Life Insurance Corporation Of India Central Office Room No. 674, 6Th Floor “Yogakshema” Jeevan Bima Marg Aayakar Bhavan, M.K. Road Nariman Point, Mumbai - 400021 Mumbai - 400020 Pan: Aaacl0582H Appellant Respondent

Section 115Section 44Section 80G

addition / disallowance to the extent of Rs. 22010,55,05,400 while determining the total income of the appellant and levying Dividend Distribution Tax (DDT) under section 115-0 of Rs.215,45,70,000. Addition of Rs. 1408,35,90,000 in respect of Interim Bonus paid to the total