https://www.taxtmi.com/caselaws?id=774959 Dividend Distribution Tax was treated as a tax on the domestic company's distributed profits, not as a tax paid on behalf of shareholders. On that basis, the dividend article in the India-UK DTAA did not apply to reduce the tax unless the treaty expressly extended protection to DDT. As no such extension was shown, the assessee could not apply the concessional treaty rate under Article 11 or claim refund of the excess tax; the claim was rejected. en-us Wed, 04 Jun 2025 00:00:00 +0530 Tue, 09 Dec 2025 12:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774959 Dividend Distribution Tax was treated as a tax on the domestic company's distributed profits, not as a tax paid on behalf of shareholders. On that basis, the dividend article in the India-UK DTAA did not apply to reduce the tax unless the treaty expressly extended protection to DDT. As no such extension was shown, the assessee could not apply the concessional treaty rate under Article 11 or claim refund of the excess tax; the claim was rejected. Case-Laws Income Tax Wed, 04 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774959