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2006 (3) TMI 67 - HC - Income Tax
DTAA entered into with any country would override the provisions of the IT Act - dividend income earned in Malaysia is not liable to be taxed in the hands of assessee in India under IT Act - Tribunal was justified in recording a finding on an issue which was not raised by the assessee either before the AO or before the CIT (A) - Having dismissed the cross-objection filed by the assessee, Tribunal was justified to decide the issue raised by the assessee on merits in their favour