https://www.taxtmi.com/caselaws?id=755558 Section 115O imposes a distinct domestic levy on distributed profits, and treaty dividend rates do not restrict dividend distribution tax unless the relevant DTAA expressly extends to that levy; excess DDT relief was therefore unavailable. Chapter XII-G's Tonnage Tax Scheme is a self-contained presumptive computation mechanism based on ship tonnage and qualifying conditions, so transfer pricing provisions under Chapter X do not alter income computed under that scheme through arm's length price adjustments. The note states that a self-contained charging or computation code prevails over general machinery provisions where the statute leaves no scope for such adjustment. en-us Mon, 29 Jan 2024 00:00:00 +0530 Sat, 13 Jul 2024 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755558 Section 115O imposes a distinct domestic levy on distributed profits, and treaty dividend rates do not restrict dividend distribution tax unless the relevant DTAA expressly extends to that levy; excess DDT relief was therefore unavailable. Chapter XII-G's Tonnage Tax Scheme is a self-contained presumptive computation mechanism based on ship tonnage and qualifying conditions, so transfer pricing provisions under Chapter X do not alter income computed under that scheme through arm's length price adjustments. The note states that a self-contained charging or computation code prevails over general machinery provisions where the statute leaves no scope for such adjustment. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755558