https://www.taxtmi.com/caselaws?id=472684 Section 115O levies additional income tax on an Indian domestic company when it declares, distributes or pays dividends. The tax is charged at the rate prescribed for the company under that provision, rather than at the rate applicable to a German resident shareholder under the India-Germany DTAA. Article 10, governing dividend taxation, does not displace Section 115O because treaty protection for this company-level levy applies only where the contracting states expressly extend it. Accordingly, distributed profits remain subject to the Section 115O rate. en-us Wed, 23 Apr 2025 00:00:00 +0530 Wed, 21 Oct 2026 19:01:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472684 Section 115O levies additional income tax on an Indian domestic company when it declares, distributes or pays dividends. The tax is charged at the rate prescribed for the company under that provision, rather than at the rate applicable to a German resident shareholder under the India-Germany DTAA. Article 10, governing dividend taxation, does not displace Section 115O because treaty protection for this company-level levy applies only where the contracting states expressly extend it. Accordingly, distributed profits remain subject to the Section 115O rate. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472684