OrbitaxIndian Tribunal rules domestic/foreign company classification under Indian tax legislation does not contravene non-discrimination clause of India-France treaty
|Treaty Development|India-France
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 28 February 2004 (reported in July 2005) in the case of Credit Lyonnais v. Deputy Commissioner of Income Tax (94 TTJ 1074) on whether a foreign company could claim a deduction for dividends received and re-distributed to its shareholders.
(a) Facts. The taxpayer (i.e. Credit Lyonnais), a company resident in France, cl…
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