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of Taxability of dividend as declared, distributed or paid by a domestic company to a non-resident shareholder(s) which attracts Additional Income Tax (Tax on Distributed Profits) referred to in Sec.115-O of the Act - such additional income tax payable by the domestic company shall be at the rate mentioned in Section 115 O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. - AT
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