Income Tax Tribunal Upholds 20.36% Dividend Distribution Tax, Rejects 15% DTAA Rate Argument for India-Thailand Agreement.

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....Levy of Dividend distribution tax (DDT) at the rate of 20.36% u/s 115O - claim of assessee that it should have been levied at the rate of 15% in terms of Article 10 of DTAA between India and Thailand - The ITAT dismisses the appeal regarding the rate of DDT, citing a previous decision that shareholders have no influence on the levy of DDT, which is an additional tax charged on distributed profits of the company.....