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2023 (2) TMI 1200 - SC ORDERWithholding rate of tax in respect of dividend - India-Swiss DTAA - Revenue, cannot but accept that the issue raised herein is covered by ‘Concentrix Services Netherlands B V case [2021 (4) TMI 1051 - DELHI HIGH COURT] - A certificate under Section 197 of the Income Tax Act, 1961 will be issued in favour of the petitioner, indicating therein, that the rate of tax, on dividend, as applicable qua the petitioner is 5% under India-Swiss DTAA. HELD THAT:- Leave granted. Arguments concluded. Judgment reserved. Learned counsel for the parties request for some time to file written submissions. Learned ASG appearing for the Revenue shall ensure that written submissions are filed within two weeks. Ld. counsel for the intervener is tasked with the responsibility of ensuring that submissions of all respondents are in place in one compilation.
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