https://www.taxtmi.com/caselaws?id=794411 Dividend Distribution Tax on dividends paid to Swiss resident shareholders was treated as covered by the India-Switzerland DTAA, because section 90(2) gives treaty benefit over the domestic rate under section 115-O. The Tribunal followed the jurisdictional High Court's view that the treaty rate for dividends cannot be ignored merely because the levy is collected from the dividend-paying company. It also recorded that the beneficial ownership objection was not a live issue before the lower authorities. DDT was therefore limited to 10% under Article 10(2), and tax paid in excess of that rate was refundable. en-us Tue, 30 Jun 2026 00:00:00 +0530 Sat, 04 Jul 2026 08:15:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794411 Dividend Distribution Tax on dividends paid to Swiss resident shareholders was treated as covered by the India-Switzerland DTAA, because section 90(2) gives treaty benefit over the domestic rate under section 115-O. The Tribunal followed the jurisdictional High Court's view that the treaty rate for dividends cannot be ignored merely because the levy is collected from the dividend-paying company. It also recorded that the beneficial ownership objection was not a live issue before the lower authorities. DDT was therefore limited to 10% under Article 10(2), and tax paid in excess of that rate was refundable. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794411