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    <title>Applicability of reduced treaty dividend rate to nonresident shareholders, directing 10% DDT and refund of excess paid</title>
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    <description>Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA&#039;s lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.</description>
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    <pubDate>Tue, 03 Feb 2026 12:02:17 +0530</pubDate>
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      <title>Applicability of reduced treaty dividend rate to nonresident shareholders, directing 10% DDT and refund of excess paid</title>
      <link>https://www.taxtmi.com/highlights?id=96567</link>
      <description>Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA&#039;s lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.</description>
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