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    <title>2025 (12) TMI 289 - ITAT DELHI</title>
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    <description>The article concerns two related tax issues: refund of excess dividend distribution tax under section 115-O and invocation of the India-Slovenia DTAA through the Most Favoured Nation clause. It states that the appeals were governed by the Special Bench decision in Dy. CIT v. Total Oil India P. Ltd., which controlled the controversy. Applying that ruling, the claim for refund of excess dividend distribution tax was rejected, and the request to extend beneficial DTAA provisions through the Most Favoured Nation clause was also not accepted. The issues were therefore decided against the assessee and in favour of the Revenue.</description>
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    <pubDate>Wed, 19 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 289 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782749</link>
      <description>The article concerns two related tax issues: refund of excess dividend distribution tax under section 115-O and invocation of the India-Slovenia DTAA through the Most Favoured Nation clause. It states that the appeals were governed by the Special Bench decision in Dy. CIT v. Total Oil India P. Ltd., which controlled the controversy. Applying that ruling, the claim for refund of excess dividend distribution tax was rejected, and the request to extend beneficial DTAA provisions through the Most Favoured Nation clause was also not accepted. The issues were therefore decided against the assessee and in favour of the Revenue.</description>
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      <pubDate>Wed, 19 Nov 2025 00:00:00 +0530</pubDate>
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