https://www.taxtmi.com/caselaws?id=468349 The Delhi HC considered whether Dividend Distribution Tax under Section 115-O is, in substance and effect, a tax on dividend income of non-resident shareholders, so that the more beneficial 10% rate under Article 11 of the India-UK DTAA could apply where the recipient shareholders are residents of the United Kingdom. It also framed the related question whether the Special Bench ruling in Total Oil India Pvt. Ltd. states the correct law. The court noted the existence of similar pending writ petitions and admitted the appeal on these questions of law, with connected matters to be tagged with the present appeal. en-us Thu, 01 Aug 2024 00:00:00 +0530 Wed, 29 Apr 2026 18:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468349 The Delhi HC considered whether Dividend Distribution Tax under Section 115-O is, in substance and effect, a tax on dividend income of non-resident shareholders, so that the more beneficial 10% rate under Article 11 of the India-UK DTAA could apply where the recipient shareholders are residents of the United Kingdom. It also framed the related question whether the Special Bench ruling in Total Oil India Pvt. Ltd. states the correct law. The court noted the existence of similar pending writ petitions and admitted the appeal on these questions of law, with connected matters to be tagged with the present appeal. Case-Laws Income Tax Thu, 01 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468349