If provisions of DTAA more beneficial then it supersedes provisions of income tax

Reverse Age Health Services Pte Ltd. Vs DCIT (ITAT Delhi) ITAT Delhi held that the provisions of a DTAA (Double Taxation Avoidance Agreement) supersedes the provisions of the income tax Act in case their application is more beneficial. Facts- Return of the assessee was selected for complete scrutiny because of the high ratio of refund of TDS. The tax deducted at source by M/s. VIC Enterprises Private Limited was on account of sale consideration of the sale of shares of Dr. Fresh Healthcare Private Limited by the assessee. These shares were acquired by the assessee on 22.08.2016 and were sold o...