Case Law Analysis
|Income Tax Appellate Tribunal
Section 115BBDA IT Act | Foreign Dividend Income Not Subject to Set-off Restriction on Unabsorbed Depreciation : ITAT Mumbai
ITAT Mumbai rules that Section 115BBDA's restriction on set-off of losses applies only to dividends from Indian companies, not foreign subsidiaries. This clarifies that unabsorbed depreciation can be lawfully adjusted against foreign dividend income, significantly benefiting multinational corporations with overseas earnings and reshaping tax planning strategies for Indian parent entities.