https://www.taxtmi.com/caselaws?id=788850 Dividend Distribution Tax under section 115-O is treated as a levy on the domestic company's distributed profits, not as tax in the hands of the shareholder, so the India-Netherlands DTAA was not triggered on the facts stated. A refund claim for excess DDT was also found not maintainable because section 239(1) requires a refund application to be made by furnishing a return in accordance with section 139, and no return had been filed. The related claim for interest under section 244A therefore also failed, and the refund request was rejected. en-us Fri, 20 Mar 2026 00:00:00 +0530 Mon, 30 Mar 2026 08:48:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788850 Dividend Distribution Tax under section 115-O is treated as a levy on the domestic company's distributed profits, not as tax in the hands of the shareholder, so the India-Netherlands DTAA was not triggered on the facts stated. A refund claim for excess DDT was also found not maintainable because section 239(1) requires a refund application to be made by furnishing a return in accordance with section 139, and no return had been filed. The related claim for interest under section 244A therefore also failed, and the refund request was rejected. Case-Laws Income Tax Fri, 20 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788850