https://www.taxtmi.com/caselaws?id=468336 The petition concerned whether dividend distribution tax paid on dividends remitted to a Japanese resident should be limited to the treaty rate under Article 10 of the India-Japan DTAA, and whether excess tax refund with statutory interest was due. The challenge was to the rejection of the request for treaty-rate application and refund. The revenue's position was that dividend distribution tax under Section 115-O was payable by the distributing company, while the dividend was exempt in the shareholder's hands under Section 10, so the statutory rate under the Act governed the levy. Notice was issued and a counter affidavit directed. en-us Wed, 08 Dec 2021 00:00:00 +0530 Wed, 29 Apr 2026 11:43:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468336 The petition concerned whether dividend distribution tax paid on dividends remitted to a Japanese resident should be limited to the treaty rate under Article 10 of the India-Japan DTAA, and whether excess tax refund with statutory interest was due. The challenge was to the rejection of the request for treaty-rate application and refund. The revenue's position was that dividend distribution tax under Section 115-O was payable by the distributing company, while the dividend was exempt in the shareholder's hands under Section 10, so the statutory rate under the Act governed the levy. Notice was issued and a counter affidavit directed. Case-Laws Income Tax Wed, 08 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468336