https://www.taxtmi.com/caselaws?id=768687 An additional legal claim may be raised before the appellate forum or DRP even if it was not made in the return or before the Assessing Officer, where the issue is purely legal and requires no fresh factual enquiry; the claim was therefore allowed. Dividend distribution tax under section 115-O is a domestic levy on the company, so the treaty rate applicable to shareholder dividend income does not restrict the tax; the DTAA could not override the domestic charge, and this ground failed. en-us Wed, 09 Apr 2025 00:00:00 +0530 Fri, 11 Apr 2025 08:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768687 An additional legal claim may be raised before the appellate forum or DRP even if it was not made in the return or before the Assessing Officer, where the issue is purely legal and requires no fresh factual enquiry; the claim was therefore allowed. Dividend distribution tax under section 115-O is a domestic levy on the company, so the treaty rate applicable to shareholder dividend income does not restrict the tax; the DTAA could not override the domestic charge, and this ground failed. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768687