https://www.taxtmi.com/caselaws?id=755558 ITAT Mumbai ruled on two issues: First, regarding DDT refund, the domestic company paying dividend distribution tax cannot claim DTAA benefits unless the contracting states specifically extend treaty protection to such companies, following Total Oil India precedent. The rate applicable is under section 115-O, not the non-resident shareholder's DTAA rate. Second, transfer pricing regulations under Chapter-X do not apply to income computed under tonnage tax scheme (Chapter XII-G) for qualifying ship operations, as expenditure alterations under transfer pricing have no bearing on TTS income computation, consistent with assessee's favorable precedents. 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 ITAT Mumbai ruled on two issues: First, regarding DDT refund, the domestic company paying dividend distribution tax cannot claim DTAA benefits unless the contracting states specifically extend treaty protection to such companies, following Total Oil India precedent. The rate applicable is under section 115-O, not the non-resident shareholder's DTAA rate. Second, transfer pricing regulations under Chapter-X do not apply to income computed under tonnage tax scheme (Chapter XII-G) for qualifying ship operations, as expenditure alterations under transfer pricing have no bearing on TTS income computation, consistent with assessee's favorable precedents. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755558