https://www.taxtmi.com/caselaws?id=468321 Dividend distribution tax under section 115-O is treated as additional income-tax on the domestic company, not as tax on the non-resident shareholder. Treaty relief under an India-UK DTAA cannot be applied to reduce that tax unless the treaty expressly extends such protection to dividend distribution tax. On that basis, the claimed restriction of tax to the DTAA rate was rejected, and no refund was admissible under section 237 because the refund claim depended solely on the asserted excess over the treaty rate. en-us Mon, 11 Nov 2024 00:00:00 +0530 Tue, 28 Apr 2026 18:02:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468321 Dividend distribution tax under section 115-O is treated as additional income-tax on the domestic company, not as tax on the non-resident shareholder. Treaty relief under an India-UK DTAA cannot be applied to reduce that tax unless the treaty expressly extends such protection to dividend distribution tax. On that basis, the claimed restriction of tax to the DTAA rate was rejected, and no refund was admissible under section 237 because the refund claim depended solely on the asserted excess over the treaty rate. Case-Laws Income Tax Mon, 11 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468321