Withholding tax on shareholder distributions limited to resident shareholders, narrowing scope of subsection and removing residency proviso. The amendment inserts the phrase 'who is resident in India' after 'distribution or payment to shareholder,' thereby confining the main clause's withholding obligation to shareholders resident in India, and simultaneously omits the same phrase from the proviso, changing the residency-based allocation of the provision's operative scope.
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Provisions expressly mentioned in the judgment/order text.
Withholding tax on shareholder distributions limited to resident shareholders, narrowing scope of subsection and removing residency proviso.
The amendment inserts the phrase "who is resident in India" after "distribution or payment to shareholder," thereby confining the main clause's withholding obligation to shareholders resident in India, and simultaneously omits the same phrase from the proviso, changing the residency-based allocation of the provision's operative scope.
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