Dividend to non-resident shareholder attracting rates u/s 115-O doesn’t have lower rate benefit under DTAA

DCIT Vs Total Oil India Pvt. Ltd (ITAT Mumbai) Dividend to non-resident shareholder attracting rates u/s 115-O doesn’t have lower rate benefit under DTAA ITAT Mumbai held that dividend declared, distributed or paid by a domestic company to a non-resident shareholder will attract Additional Income Tax (Tax on Distributed Profits) referred to in Sec.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. Facts- The assessee declared/paid dividend during the previous year relevant to AY 2016-17. One of the shareholder to whom ...