https://www.taxtmi.com/caselaws?id=783137 Dividend distribution tax on dividends paid by a domestic company to a United Kingdom resident shareholder was treated as falling within the India-UK tax treaty, because the underlying payment remained dividend income even though the tax was collected from the company. Section 115-O was characterised as a collection mechanism introduced for administrative convenience, not as changing the nature of the income. As Article 11 specifically governs dividends and section 90 gives effect to the more beneficial treaty provision, the treaty cap prevailed. The source-state taxing right was therefore limited to 10%, and the domestic company was entitled to the treaty rate. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 10 Dec 2025 12:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783137 Dividend distribution tax on dividends paid by a domestic company to a United Kingdom resident shareholder was treated as falling within the India-UK tax treaty, because the underlying payment remained dividend income even though the tax was collected from the company. Section 115-O was characterised as a collection mechanism introduced for administrative convenience, not as changing the nature of the income. As Article 11 specifically governs dividends and section 90 gives effect to the more beneficial treaty provision, the treaty cap prevailed. The source-state taxing right was therefore limited to 10%, and the domestic company was entitled to the treaty rate. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783137