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.

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