Domestic Company Denied Refund of Excess Dividend Tax; DTAA Benefits Require Explicit Intention by Contracting States.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Refund of excess Dividend Distribution Tax (“DDT”) paid by the assessee - wherever the Contracting States to a tax treaty intend to extend the treaty protection to the domestic company paying dividend distribution tax, only then, the domestic company can claim benefit of the DTAA, if any. - Claim denied - AT....