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
57. BFAR has based its decision on the definitional and conceptual framework of DDT holding that if it paid by the petitioner to its shareholder, it falls outside scope of DTAA as, (a) Dividend is an amount declared, distributed or paid by the Domestic
Company out of the current or accumulated profits; (b) Dividend is additional income tax payable over
