Manmohan Textiles Ltd v. NFAC ( 2023) BCAJ -January – P. 32( Mum)( Trib)

S. 10(34) :Dividend – Domestic companies – Tax on distribution of profits – Dividend received during FY. 2019 -20 relevant to AY. 2020- 21 cannot be taxed . [S. 115O, 154 ]

Allowing the appeal of the assessee the Tribunal held that the second proviso to section 10(34) categorically states that dividends received on or after 1 st April 2020 alone would be subjected to tax . On the facts the dividend was received during FY. 2019 -20 relevant to AY. 2020-21 therefore not taxable during the year under consideration . ( ITA No. 1884/ Mum/ 2022 dt. 6 -9 -2022)  ( AY. 2020 -21 )