https://www.taxtmi.com/caselaws?id=763275 Dividend distribution tax under section 115-O is a separate levy on the domestic company on distributed profits, not a tax paid on behalf of the shareholder. Applying the Special Bench view in Total Oil India (P.) Ltd., the Tribunal held that Article 11 of the India-Italy treaty could not be used to reduce the statutory DDT rate unless the treaty expressly extended its protection to that levy. The assessee therefore was not entitled to restrict DDT to the treaty rate or to obtain a refund of the excess tax. en-us Mon, 05 Aug 2024 00:00:00 +0530 Mon, 16 Dec 2024 18:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763275 Dividend distribution tax under section 115-O is a separate levy on the domestic company on distributed profits, not a tax paid on behalf of the shareholder. Applying the Special Bench view in Total Oil India (P.) Ltd., the Tribunal held that Article 11 of the India-Italy treaty could not be used to reduce the statutory DDT rate unless the treaty expressly extended its protection to that levy. The assessee therefore was not entitled to restrict DDT to the treaty rate or to obtain a refund of the excess tax. Case-Laws Income Tax Mon, 05 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763275