https://www.taxtmi.com/caselaws?id=764393 The ITAT Chennai held that dividend distribution tax paid by a domestic company under section 115-O cannot benefit from DTAA rates applicable to non-resident shareholders. Following the Total Oil India precedent, the tribunal ruled that additional income tax on distributed profits must be paid at rates specified in section 115-O, not at DTAA rates for dividend income to non-residents. Treaty protection for domestic companies paying dividend distribution tax requires specific provision in the DTAA between contracting states. The case was decided against the assessee. en-us Tue, 07 Jan 2025 00:00:00 +0530 Thu, 09 Jan 2025 07:46:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764393 The ITAT Chennai held that dividend distribution tax paid by a domestic company under section 115-O cannot benefit from DTAA rates applicable to non-resident shareholders. Following the Total Oil India precedent, the tribunal ruled that additional income tax on distributed profits must be paid at rates specified in section 115-O, not at DTAA rates for dividend income to non-residents. Treaty protection for domestic companies paying dividend distribution tax requires specific provision in the DTAA between contracting states. The case was decided against the assessee. Case-Laws Income Tax Tue, 07 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764393