Section 9 – Dividend – Notice issued in SLP filed against order of the HC that dividend received by a Switzerland based company from an Indian company would bear a lower withholding tax rate of 5% instead of 10% in view of MFN clause in protocol to India-Switzerland DTAA.
Income-tax Officer v. Golderma Pharma SA World Trade Centre – [2023] 147 taxmann.com 517 (SC).