Domestic Companies Must Levy Dividend Tax on Non-Residents per Income Tax Act, Not DTAA; Refund Claims Denied.

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....Taxability of dividends - dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s) - The Tribunal held that, 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. - Claim of refund of excess Dividend Distribution Tax (DDT) rejected.....