https://www.taxtmi.com/caselaws?id=468183 Dividend Distribution Tax under section 115O is chargeable at the statutory rate on distributed profits, and treaty rates applicable to non-resident shareholders do not automatically reduce that liability. The Special Bench reasoning in Total Oil India Pvt. Ltd. was followed: treaty protection can extend to the domestic company only where the relevant DTAA expressly covers dividend distribution tax. On that basis, the claimed reduction of DDT and the related refund were rejected, and the levy at the statutory rate was upheld. en-us Mon, 03 Feb 2025 00:00:00 +0530 Tue, 21 Apr 2026 08:48:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468183 Dividend Distribution Tax under section 115O is chargeable at the statutory rate on distributed profits, and treaty rates applicable to non-resident shareholders do not automatically reduce that liability. The Special Bench reasoning in Total Oil India Pvt. Ltd. was followed: treaty protection can extend to the domestic company only where the relevant DTAA expressly covers dividend distribution tax. On that basis, the claimed reduction of DDT and the related refund were rejected, and the levy at the statutory rate was upheld. Case-Laws Income Tax Mon, 03 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468183