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    <title>2026 (2) TMI 154 - ITAT AHMEDABAD</title>
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    <description>Dividend tax on payments to UK resident shareholders was held subject to the more beneficial treaty rate, so the domestic rate could not override the 10% ceiling and excess tax was refundable. Interest under sections 234B and 234C was found unsustainable on incremental income arising only after the advance pricing agreement and modified return, because the additional liability had not crystallised in time for advance tax computation. TDS credit was not rejected on merits; the assessing authority was directed to verify the records and grant lawful credit.</description>
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