GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD - 1(1), PANAJI
In the result, the appeal filed by the assessee is partly allowed for statistical purpose
ITA 344/PAN/2017[2013-14]Status: DisposedITAT Panaji02 Apr 2026AY 2013-14
Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.344/Pan/2017 (A.Y.2013-14 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Sesa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent
For Appellant: Shri.Niraj Sheth. ARFor Respondent: Shri.Renga Ranjan.CIT DR
Section 115Section 143(3)Section 144C(5)Section 2(43)Section 4Section 90
exempt from tax. Article 11 therefore, restricts the right of India, as a source State, to levy tax in accordance with its domestic laws, that is, Section 115-O, but instead of the rate prescribed for therein, the tax has to be levied at the minimum rate of 10% to the extent the dividend is paid to a resident