https://www.taxtmi.com/caselaws?id=778161 Dividend distribution tax under section 115-O is chargeable on the domestic company at the statutory rate, and treaty protection for dividend income does not automatically extend to the company unless the treaty expressly provides for such relief. Applying the Special Bench ruling in Total Oil India (P.) Ltd., the tribunal held that Article 11 of the India-Germany DTAA could not be used to claim refund of excess dividend distribution tax paid by the assessee. The refund claim was rejected, and the assessment under section 115-O remained undisturbed. en-us Mon, 08 Sep 2025 00:00:00 +0530 Thu, 11 Sep 2025 08:29:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778161 Dividend distribution tax under section 115-O is chargeable on the domestic company at the statutory rate, and treaty protection for dividend income does not automatically extend to the company unless the treaty expressly provides for such relief. Applying the Special Bench ruling in Total Oil India (P.) Ltd., the tribunal held that Article 11 of the India-Germany DTAA could not be used to claim refund of excess dividend distribution tax paid by the assessee. The refund claim was rejected, and the assessment under section 115-O remained undisturbed. Case-Laws Income Tax Mon, 08 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778161