https://www.taxtmi.com/caselaws?id=775779 Dividend distribution tax under section 115-O was treated as a levy on the distributing company's profits, not on the non-resident shareholder's dividend income, so treaty relief was unavailable unless the treaty expressly protected the company paying the tax. The additional appellate claim was nevertheless entertained despite not being raised in the return, but it failed on merits because section 115-O remained applicable to the distribution. The assessee's challenge was rejected on the main tax issue, and the remaining grounds were not pursued. en-us Fri, 25 Jul 2025 00:00:00 +0530 Thu, 31 Jul 2025 08:17:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775779 Dividend distribution tax under section 115-O was treated as a levy on the distributing company's profits, not on the non-resident shareholder's dividend income, so treaty relief was unavailable unless the treaty expressly protected the company paying the tax. The additional appellate claim was nevertheless entertained despite not being raised in the return, but it failed on merits because section 115-O remained applicable to the distribution. The assessee's challenge was rejected on the main tax issue, and the remaining grounds were not pursued. Case-Laws Income Tax Fri, 25 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775779