“Section 115(0)”

Section References (mined)Section 115Section 115(0)3 judgments

ACIT CIRCLE-1(2)(1), MUMBAI vs. BLUE DART EXPRESS LIMITED, MUMBAI

In the result, the appeal filed by the revenue is allowed

ITA 2505/MUM/2022[2018-2019]Status: DisposedITAT Mumbai26 Mar 2024AY 2018-2019

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Richa SachdevaFor Respondent: Shri Ashok Kumar Ambastha

115-0 of the Act, such additional income tax payable by the company shall be at the rate mentioned in Section 115 0 of the Act and not at the 5 rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference ... Express Singapore Pte Limited, being a non resident share holder and the dividend distribution tax(DDT) shall be at the rate mentioned in section 115(0) of the Act is applicable and not at the rate of tax applicable to nonresident share holders as specified in the relevant DTAA

MITSUI KINZOKU COMPONENTS INDIA PRIVATE LIMITED,REWARI vs. DCIT, CIRCLE, REWARI

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

ITA 1165/DEL/2022[2016-17]Status: DisposedITAT Delhi21 Jun 2023AY 2016-17

Bench: Sh. N. K. Billaiya & Sh. C.N. Prasadassessment Year: 2016-17 Mitsui Kinzoku Dcit Components India Pvt. Ltd. Vs Circle Plant No.242-243, Industrial Rewari Growth, Centre, Sector-3 Bawal, Rewari-123501 Pan No.Aaecm3062B (Appellant) (Respondent)

Section 115(0)Section 250Section 90(2)

accordance with the more beneficial tax rate prescribed under India-Japan DTAA, which is applicable as per section 90(2) vis-a-vis section 115(0) of the Act, thereby denying the relief of INR 2,90,01,412/- to the appellant. 2.1. That the Ld. CIT(A) has grossly

DCIT 1(2)(1), MUMBAI vs. M/S. BLUE DART EXPRESS LTD., MUMBAI

ITA 1370/MUM/2022[1370]Status: DisposedITAT Mumbai15 Jun 2023

Bench: Shri B R Baskaran & Shri Pavan Kumar Gadale

Section 10(34)Section 143(2)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL, “I” BENCH MUMBAI. BEFORE SHRI B R BASKARAN, ACCOUNTANT MEMBER & SHRI PAVAN KUMAR GADALE