https://www.taxtmi.com/caselaws?id=790726 Dividend distribution tax under section 115-O was analysed as to whether it is a tax on the company's profits or on the shareholder's dividend income for India-UK treaty purposes. The text notes that earlier authorities, including a Supreme Court-approved Division Bench view, treated the levy as one on the company's profits, while a later Division Bench took a contrary position. Because the co-ordinate Bench decisions appeared irreconcilable, the controversy was considered fit for reference to a Larger Bench for authoritative determination on the correctness of the later view and whether it was per incuriam. No final ruling on tax liability or refund was given. en-us Mon, 27 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790726 Dividend distribution tax under section 115-O was analysed as to whether it is a tax on the company's profits or on the shareholder's dividend income for India-UK treaty purposes. The text notes that earlier authorities, including a Supreme Court-approved Division Bench view, treated the levy as one on the company's profits, while a later Division Bench took a contrary position. Because the co-ordinate Bench decisions appeared irreconcilable, the controversy was considered fit for reference to a Larger Bench for authoritative determination on the correctness of the later view and whether it was per incuriam. No final ruling on tax liability or refund was given. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790726