ITAT Allows DTAA Benefit on Dividend Distribution Tax as DDT is Tax on Shareholder Income

Metal One Corporation India Private Limited Vs DCIT (ITAT Delhi) DDT Cannot Exceed Treaty Rate Because Tax Treaty Prevails Over Domestic Law; ITAT Grants Refund Claim on Excess DDT Because Treaty Rate of 10% Applied to Foreign Shareholders; Corporate Club Membership Fees Allowed as Business Expenditure Because Used for Business Purposes; ITAT Rejects Revenue Stand on DDT Because Treaty Protection Applies to Dividend Payments; DTAA Benefit Available on Dividend Distribution Tax Because DDT Covered Within Income Tax. In , the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) dealt with app...