TIMKEN INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR
In the result, appeal of the assessee stands partly allowed
ITA 92/RAN/2022[2017-18]Status: DisposedITAT Ranchi12 Jun 2025AY 2017-18
Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)
For Appellant: S/Shri K.M.Gupta/Krishan Shaw, ARsFor Respondent: Smt. Rinku Singh, CIT DR
Section 115JSection 14ASection 234D
deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence
