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“Section 90(2)”

Section References (mined)Section 90Section 90(2)547 judgments

The decision most relied on for Section 90(2) is Union of India v. Azadi Bachao Andolan (263 ITR 706), cited in 691 judgments on BharatTax.

Leading authorities on Section 90(2)

Union of India v. Azadi Bachao Andolan
263 ITR 706 · 2003 · Supreme Court
691
citing judgments

A citizen is free to carry on business within the law, and mere tax planning without a motive to evade taxes through colorable devices is not frowned upon. The liability to taxation, for the purpose of tax treaty application, is a legal situation, not the fiscal fact of actual payment.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

Asia Satellite Telecommunications Co. Ltd. v. DIT
332 ITR 340 · 2011 · High Court
359
citing judgments

Payments for the use of equipment, such as satellite transponders, do not constitute 'royalty' under Section 9(1)(vi) of the Income-tax Act, 1961, or under applicable tax treaties, especially when there is no transfer of the right to use a process or underlying technology.

DIT v. New Skies Satellite BV
382 ITR 114 · 2016 · High Court
325
citing judgments

An amendment to the Income Tax Act, such as the Finance Act, 2012 amendment to Section 9(1)(vi) defining royalty, does not automatically override or alter the definition of 'royalty' as provided in a Double Taxation Avoidance Agreement (DTAA) unless the DTAA itself is bilaterally amended. The definition of royalty in a DTAA remains unaffected by unilateral changes to domestic law.

CIT v. Siemens Aktiongesellschaft
310 ITR 320 · 2009 · High Court
259
citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

Skycell Communications Ltd. v. DCIT
251 ITR 53 · 2001 · High Court
253
citing judgments

Technical services involve human intervention and expertise, not just routine or machine-based operations. Routine customer support and standard facility provision through technology do not constitute technical services under the Act.

Shivsagar Veg Restaurant v. ACIT
317 ITR 433 · 2009 · High Court
202
citing judgments

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

153 (Gujarat) 8 Shakti Karnawat v. ITO
296 ITR 90 · 2008 · High Court
171
citing judgments

A live link of third-party information can form the basis for reopening an assessment under Section 148, provided it contains material facts necessary for assessment. The Assessing Officer must demonstrate a "reason to believe" that income has escaped assessment, which can be satisfied by such information even if it pertains to other assessees or relates to accommodation entries.

Judgments citing Section 90(2)

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-2, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 1783/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Treaty ('DTAA') being more beneficial to the Appellant than the provisions of the Income-tax Act, 1961 ('the Act') and by virtue of section 90(2) of the Act. ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 4 1.5. Without prejudice to the above, on the facts and in the circumstances

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-1, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 2390/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Treaty ('DTAA') being more beneficial to the Appellant than the provisions of the Income-tax Act, 1961 ('the Act') and by virtue of section 90(2) of the Act. ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 4 1.5. Without prejudice to the above, on the facts and in the circumstances

Gac Marine Llc, Gurgaon vs. ITO, Ward 1(3)(2), International Taxation, New Delhi

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2018/DEL/2023[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishragac Marine Llc Vs. Ito, Ward – 1(3)(2), 1St Floor, Ahip Palms, International Taxation, Plot No.242 & 243, New Delhi – 110 002 Phase-Iv, Gurgaon Haryana – 122 015 Pan : Aaecg 2882 R (Appellant) (Respondent) Assessee By Shri Gaurav Singhal, Adv. & Ms. Mahima Jain, Adv. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 28/11/2024 Date Of Pronouncement 18/12/2024 O R D E R Per Vimal Kumar, Jm:

Section 142(1)Section 144Section 147Section 148Section 195Section 90(2)

appellant are not taxable in India as per the Double Taxation Avoidance Agreement (‘DTAA’) between India and UAE read with section 90(2) of the Act. The learned CIT(A) grossly erred by considering total receipts of appellant as Rs.10,06,14,234/- whereas, the actual receipts of the appellant

Kreuz Challenger Pte Ltd, Singapure vs. ACIT, International Taxation Circle2(1)(2), New Delhi

The appeal of the assessee is allowed

ITA 2373/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Dec 2024AY 2019-20

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2019-20 Kreuz Challenger Pte Ltd., Vs Acit, 2, Venture Drive, International Taxation #24-01 Vision Exchange, Circle 2(1)(2), Singapore , 999999 New Delhi. Pan : Aahck3082A

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms C. Chandra Kanta, CIT-DR
Section 115ASection 143(3)Section 144C(13)Section 197Section 44BSection 44DSection 9(1)(vi)Section 9(1)(vii)Section 90(2)

failed to appreciate that the Appellant being a resident of Singapore, is eligible to avail beneficial treaty provisions as per section 90(2) of the Act. Accordingly, in absence of PE in India in terms of Article 5 read with Article 7 of the India- Singapore tax treaty (‘DTAA’), income

Surrendra Kumar Goenka, Howrah vs. ADIT, CPC, Bengaluru / I.T.O., Ward 61(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1831/KOL/2024[2020-2021]Status: DisposedITAT Kolkata05 Dec 2024AY 2020-2021

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 139(1)Section 143(1)Section 234ASection 5Section 90

tune of Rs. 17,72,470/- was deducted in United Kingdom under DTAA between India and UK and provision of Section 90(2) of the Act. We also note that Rule 128 sub-Rule 9 provides that Form-67 should be filed on or before the due date of filing

Debanjan Chatterjee, Kolkata vs. D.D.I.T., CPC, Bengaluru, Bengalore

In the result, the appeal of the assessee is allowed

ITA 1959/KOL/2024[2021-2022]Status: DisposedITAT Kolkata02 Dec 2024AY 2021-2022

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 1959/Kol/2024 Assessment Year: 2021-2022 Debanjan Chatterjee,……..…………….…………Appellant C-3/14, East Enclave Cooperative Society, Rajarhat, Kolkata-700156 [Pan:Aezpc7707H] -Vs.- Deputy Director Of Income Tax,………………Respondent Cpc, Bengluru, Bangalore-560500 Appearances By: Shri Nilesh Kariya, A.R., Appeared On Behalf Of The Assessee Shri Sanjay Paul, Addl. Cit,Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 28, 2024 Date Of Pronouncing The Order: December 02, 2024 O R D E R

Section 139Section 139(4)Section 143(1)Section 154Section 90

tune of Rs. 17,72,470/- was deducted in United Kingdom under DTAA between India and UK and provision of Section 90(2) of the Act. We also note that Rule 128 sub-Rule 9 provides that Form-67 should be filed on or before the due date of filing

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7366/DEL/2019[2016-17]Status: DisposedITAT Delhi29 Nov 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1008/DEL/2019[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 8081/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Nov 2024AY 2013-14

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4716/DEL/2018[2015-16]Status: DisposedITAT Delhi29 Nov 2024AY 2015-16

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2893/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6332/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

M/S. Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1009/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Nov 2024AY 2011-12

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

charges are treated as managerial services under the Income Tax Act, only the technical or consultancy services are prescribed in DTAA. As per section 90(2), the income tax Act or DTAA whichever is more beneficial will be applicable. As the DTAA has restricted meaning of 'fees for technical services ... said DTAA. There is a restrictive definition of FTS provided in DTAA and it will, on account of the provision of section 90(2) of the Act, have precedence over the wider definition provided in Explanation 2 of section 9(1)(vii) which includes managerial, technical or consultancy services

Kalidoss Natarajan, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(3)(1), Bangalore

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

ITA 1976/BANG/2024[2019-20]Status: DisposedITAT Bangalore28 Nov 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Shri Balaji V, C.AFor Respondent: Shri V Parithivel, JCIT (DR)
Section 139(1)Section 143(1)

Delhi)CIT v. ACE Multitaxes Systems (P.) Ltd. [2009] 317 ITR 207 (Karnataka). 13. It was submitted that as per the provisions of section 90(2) of the Act, where the Central Government of India has entered into a DTAA, the provisions of the Act would apply to the extent

Neetu Agarwal, Kolkata vs. Income Tax Officer, Kolkata

The appeal of the assessee is allowed

ITA 1898/KOL/2024[2021-22]Status: DisposedITAT Kolkata18 Nov 2024AY 2021-22

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1898/Kol/2024 Assessment Year: 2021-22 Neetu Agarwal………………………………………………………….…..……Appellant Flat 6C, Block 2, Shree Ramnagar Residential Complex, Vip Road, Tegharia, W.B – 700052. [Pan: Actpa2426P] Vs. Ito, Kolkata……………..............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Puja Agarwal, A.R, Appeared On Behalf Of The Appellant. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2024 Date Of Pronouncing The Order : November 18, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Against The Order Dated 11.07.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee Is A Resident Individual, Who Filed Her Return Of Income On 29.12.2021 For The Financial Year 2020-21 Relevant To Assessment Year 2021-22 Reporting A Total Income Of Rs.25,58,440/-. The Assessee Discharged Her Tax Liability By Way Of Tax Deducted At Source Amounting To Rs.2,80,028/-, Self-Assessment Tax Of Rs.22,740/- & Foreign Tax Credit (‘Ftc’) Of Rs.2,25,936/-. The Assessee Also Filed Form.67 Which Was Filed On 25.01.2022. An Intimation U/S 143(1) Of The Act Was Issued On 28.10.2022 In Which The Ftc Was Not Provided To The Assessee. This Disallowance Resulted In Tax Demand Of Rs.2,79,130/-.

Section 139(1)Section 143(1)Section 154Section 250Section 90

beneficial to the assessee: 165.The conclusions in the aforestated paragraph have no direct relevance to the facts at hand as the effect of section 90(2) of the Income Tax Act, read with explanation 4 thereof, is to treat the DTAA provisions as the law that must be followed

Foseco India Limited, Pune vs. ACIT Circle 1(1), Pune

In the result, the appeal of the assessee for AY 2014-15 is dismissed

ITA 1120/PUN/2024[2020-21]Status: DisposedITAT Pune11 Nov 2024AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Atul PoddarFor Respondent: Shri Ramnath P. Murkunde
Section 115Section 115JSection 237

restricted @10% as per of Article 11 of the India-UK Double Taxation Avoidance Agreement (the DTAA' or the tax treaty) read with section 90(2) of the Act. It is seen that section 90 is under Chapter IX of the Income Tax Act which is on double taxation relief ... This primarily deals with non-resident assesses and section 90(2) states the principle for granting relief of tax for non-resident assesses for avoidance of double taxation. It is not furnished how the dividends have been taxed in both India and UK for the non- resident parent entity

Foseco India Limited, Pune vs. ACIT, Circle1(1), Pune

In the result, the appeal of the assessee for AY 2014-15 is dismissed

ITA 1119/PUN/2024[2019-20]Status: DisposedITAT Pune11 Nov 2024AY 2019-20

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Atul PoddarFor Respondent: Shri Ramnath P. Murkunde
Section 115Section 115JSection 237

restricted @10% as per of Article 11 of the India-UK Double Taxation Avoidance Agreement (the DTAA' or the tax treaty) read with section 90(2) of the Act. It is seen that section 90 is under Chapter IX of the Income Tax Act which is on double taxation relief ... This primarily deals with non-resident assesses and section 90(2) states the principle for granting relief of tax for non-resident assesses for avoidance of double taxation. It is not furnished how the dividends have been taxed in both India and UK for the non- resident parent entity

Foseco India Limited, Pune vs. ACIT, Circle 1 (1), Pune

In the result, the appeal of the assessee for AY 2014-15 is dismissed

ITA 1118/PUN/2024[2018-19]Status: DisposedITAT Pune11 Nov 2024AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Atul PoddarFor Respondent: Shri Ramnath P. Murkunde
Section 115Section 115JSection 237

restricted @10% as per of Article 11 of the India-UK Double Taxation Avoidance Agreement (the DTAA' or the tax treaty) read with section 90(2) of the Act. It is seen that section 90 is under Chapter IX of the Income Tax Act which is on double taxation relief ... This primarily deals with non-resident assesses and section 90(2) states the principle for granting relief of tax for non-resident assesses for avoidance of double taxation. It is not furnished how the dividends have been taxed in both India and UK for the non- resident parent entity

Foseco India Limited, Pune vs. ACIT Circle 1(1), Pune

In the result, the appeal of the assessee for AY 2014-15 is dismissed

ITA 1117/PUN/2024[2017-18]Status: DisposedITAT Pune11 Nov 2024AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Atul PoddarFor Respondent: Shri Ramnath P. Murkunde
Section 115Section 115JSection 237

restricted @10% as per of Article 11 of the India-UK Double Taxation Avoidance Agreement (the DTAA' or the tax treaty) read with section 90(2) of the Act. It is seen that section 90 is under Chapter IX of the Income Tax Act which is on double taxation relief ... This primarily deals with non-resident assesses and section 90(2) states the principle for granting relief of tax for non-resident assesses for avoidance of double taxation. It is not furnished how the dividends have been taxed in both India and UK for the non- resident parent entity

Foseco India Limited, Pune vs. ACIT, Circle 1(!), Pune

In the result, the appeal of the assessee for AY 2014-15 is dismissed

ITA 1116/PUN/2024[2016-17]Status: DisposedITAT Pune11 Nov 2024AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Atul PoddarFor Respondent: Shri Ramnath P. Murkunde
Section 115Section 115JSection 237

restricted @10% as per of Article 11 of the India-UK Double Taxation Avoidance Agreement (the DTAA' or the tax treaty) read with section 90(2) of the Act. It is seen that section 90 is under Chapter IX of the Income Tax Act which is on double taxation relief ... This primarily deals with non-resident assesses and section 90(2) states the principle for granting relief of tax for non-resident assesses for avoidance of double taxation. It is not furnished how the dividends have been taxed in both India and UK for the non- resident parent entity