SC to Decide Whether Dividend Distribution Tax Is Tax on Dividend or Distributed Profits

JCIT Vs Colorcon Asia Pvt. Ltd. (Supreme Court of India) In JCIT Vs Colorcon Asia Pvt. Ltd., the Supreme Court considered substantial questions of law relating to the nature of Dividend Distribution Tax (DDT) under Section 115-O of the Income Tax Act, 1961, and its interaction with the India-UK Double Taxation Avoidance Agreement (DTAA). The Supreme Court framed three substantial questions for consideration: whether DDT under Section 115-O is a tax on distributed profits or a tax on dividend; whether DDT paid on dividends distributed to a UK resident can be levied at a rate higher than that pe...