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of Income accrued in India - dividend income - DDT is levy on the dividend distributed by the payer company, being an additional tax is covered by the definition of ‘Tax’ as defined u/s 2(43) of the Act which is covered by the charging section 4 of the Act and charging section itself is subject to the provisions of the Act which would include section 90 of the Act. - DDT levied by the appellant should not exceed the rate specified in Article 10 in India Germany DTAA - AT
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