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Double Taxation Avoidance Agreement Unavailable for Refunds on Domestic Dividend Distribution Taxes.
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....Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.....