https://www.taxtmi.com/caselaws?id=791406 Dividend Distribution Tax under section 115-O was treated as a dividend-linked levy within the income-tax regime, so section 90(2) allowed the more beneficial treaty provision under Article 10 to cap the tax rate and justify refund of excess tax. Club membership fees were held to be revenue expenditure incurred wholly and exclusively for business, not a personal or capital outlay, so the disallowance under section 37 was deleted. Both issues were decided in favour of the assessee. en-us Fri, 08 May 2026 00:00:00 +0530 Mon, 11 May 2026 09:50:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791406 Dividend Distribution Tax under section 115-O was treated as a dividend-linked levy within the income-tax regime, so section 90(2) allowed the more beneficial treaty provision under Article 10 to cap the tax rate and justify refund of excess tax. Club membership fees were held to be revenue expenditure incurred wholly and exclusively for business, not a personal or capital outlay, so the disallowance under section 37 was deleted. Both issues were decided in favour of the assessee. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791406