S. 90 : Double taxation relief-Not made arrangements for declaration of dividends out of income earned in India-Income was to be charged at a higher rate of tax in India vis-à-vis domestic company and same could not be treated as discrimination on account of fact that assessee belonged to other Contracting State, i.e. Korea-DTAA-India-Korea. [S. 9(1)(i), Art, 25]
Shinhan Bank v. Dy. DIT (IT) (2022) 218 TTJ 401 / 217 DTR 113 / 139 taxmann.com 563 (Mum)(Trib)