Supreme Court · 2023 INSC 834 · Decided 15 September 2023
Principal Commissioner of Income TAX-10 v. M/S Krishak Bharti Cooperative LTD.
- Court
- Supreme Court of India
- Citation
- 2023 INSC 834 · [2023] 12 S.C.R. 590
- Case number
- CIVIL APPEAL No. 836/2018
- Decided
- 15 September 2023
- Bench
- B.V. NAGARATHNA, PRASHANT KUMAR MISHRA (2-judge bench)
- Outcome
- Dismissed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act Section 143(3)
Headnote
HEADNOTES Issue for consideration: Whether the dividend income earned by the assessee is taxable, although exempted under Omani Tax Laws to entitle the assessee to the benefits of the Double Taxation Avoidance Agreement (DTAA) between India DTAA and Omani Tax Laws - Benefit to the assessee under: Held: A clarification letter dated 11.12.2000 (interpreting the provisions contained in Article 8 and Article 8 (bis) of the Omani Tax Laws) addressed by the Secretary General for Taxation, Sultanate of Oman, Ministry of Finance
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