Dividend distribution tax is a tax on domestic company distributing dividend

Ambuja Cement Ltd Vs ACIT-LTU (ITAT Mumbai)

The additional grounds of appeal of the assessee is pertained to the applicability of dividend distribution tax at the rate of 5% to the dividend declared by the assessee to Holderind Investment Ltd., Mauritius and the assessee sought the benefit of article 10 of the India-Mauritius Double Tax Avoidance Agreement. At the outset Ld Counsel agreed that identical issue and similar facts has been decided by the Special Bench of ITAT Mumbai in the case of DCIT v/s Total Oil India Pvt. L

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