https://www.taxtmi.com/highlights?id=102877 Dividend distribution tax on dividends paid to a Netherlands-resident shareholder raises the question whether the lower India-Netherlands DTAA rate overrides the domestic rate under Section 115-O. Although High Court authority supported treaty-rate application, the issue was pending before the Supreme Court, which had advised High Courts to consider stays in matters involving the same controversy. Applying judicial discipline, the Tribunal declined to decide the treaty-rate claim pending Supreme Court adjudication. The appellate order was set aside and remanded for fresh adjudication in line with the Supreme Court's eventual decision. en-us Thu, 20 Aug 2026 08:14:28 +0530 Thu, 20 Aug 2026 08:14:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102877 Dividend distribution tax on dividends paid to a Netherlands-resident shareholder raises the question whether the lower India-Netherlands DTAA rate overrides the domestic rate under Section 115-O. Although High Court authority supported treaty-rate application, the issue was pending before the Supreme Court, which had advised High Courts to consider stays in matters involving the same controversy. Applying judicial discipline, the Tribunal declined to decide the treaty-rate claim pending Supreme Court adjudication. The appellate order was set aside and remanded for fresh adjudication in line with the Supreme Court's eventual decision. Highlights Income Tax Thu, 20 Aug 2026 08:14:28 +0530 https://www.taxtmi.com/highlights?id=102877