https://www.taxtmi.com/caselaws?id=775786 Dividend distribution tax under section 115-O was treated as a tax on the domestic company's income, not on the non-resident shareholder's dividend income. On that basis, the Tribunal held that the applicable DTAA rate for dividend income could not be invoked to restrict the company's domestic tax liability. The treaty provisions governing taxation of the shareholder therefore did not control the company's obligation under section 115-O, and the claim for treaty-based reduction was rejected. en-us Tue, 29 Jul 2025 00:00:00 +0530 Thu, 31 Jul 2025 08:17:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775786 Dividend distribution tax under section 115-O was treated as a tax on the domestic company's income, not on the non-resident shareholder's dividend income. On that basis, the Tribunal held that the applicable DTAA rate for dividend income could not be invoked to restrict the company's domestic tax liability. The treaty provisions governing taxation of the shareholder therefore did not control the company's obligation under section 115-O, and the claim for treaty-based reduction was rejected. Case-Laws Income Tax Tue, 29 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775786