GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD-1(1), PANAJI., PANAJI
In the result, the appeal filed by the assessee is partly allowed for statistical purpose
ITA 62/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Jul 2025AY 2012-13
Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.62/Pan/2017 (A.Y.2012-13 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Seasa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent
For Appellant: Shri.Nirajsheth. ARFor Respondent: Shri.Satish M .CIT DR
Section 115Section 143(3)Section 144C(5)
5. We considering the facts, circumstances and ratio of judicial decisions and Special bench decision fallow the judicial precedence and observe that the Dividend Distribution Tax (DDT) on dividend declared and paid by the assessee to a non resident Netherlands share holder shall be at the rate mentioned in section 115(O) of the Act is applicable