https://www.taxtmi.com/highlights?id=99646 Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed. en-us Mon, 11 May 2026 09:50:58 +0530 Mon, 11 May 2026 09:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99646 Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed. Highlights Income Tax Mon, 11 May 2026 09:50:58 +0530 https://www.taxtmi.com/highlights?id=99646