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Issues: Whether the appeal raised questions of law warranting consideration, including the tax character of dividend distribution tax under section 115-O of the Income-tax Act, 1961 in relation to non-resident shareholders and the applicability of the more beneficial rate under Article 11 of the India-United Kingdom DTAA, and whether the Special Bench decision in Deputy Commissioner of Income Tax v. Total Oil India Pvt. Ltd. lays down the correct law.
Outcome: The appeal was admitted on the stated questions of law, and the connected writ petitions were tagged with it.
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