Domestic companies must pay dividend tax per section 115-O, not DTAA rates, unless treaty covers domestic entities.

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....Refund of excess Dividend Distribution Tax - additional income tax payable by the domestic company shall be at the rate mentioned in section 115-O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. - 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 - AT....