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2011 (5) TMI 588 - AT - Income TaxNotional interest on deposit - India USA DTAA - Held that:- CIT(A) in assessment years 1993-94 to 1999-2000 stated that when the recovery of principal amounts itself is doubtful to be realized from the debtors, there is no justification to contemplate any notional interest by way of income in the hands of the assessee company - in favour of the assessee Tax paid in USA on the income accrued to the assessee - CIT(A) directed to tax the foreign dividend in net amount after deducting the foreign tax - Held that:- There is no justification in straightaway excluding the tax withheld in those countries from the dividend income to be included in the impugned assessments - Appeal is allowed by way of remand
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