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“dividend distribution tax”

Special Rate ProvisionsSection 115-OSection 115-O587 judgments

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1783/KOL/2024[2015-2016]Status: DisposedITAT Kolkata20 Mar 2026AY 2015-2016

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\N\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N\N2.

Section 115Section 244ASection 250

circumstances of the case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n\n2. That on the facts and circumstances of the case ... assessee had\ndeclared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006-\n07 to Philips Netherlands, on which Dividend Distribution Tax (DDT)\nof ₹2,30,36,643/- was paid at the rate of 16.995% as per the\nprovisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1782/KOL/2024[2014-2015]Status: DisposedITAT Kolkata20 Mar 2026AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

circumstances of the case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case ... assessee had declared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006- 07 to Philips Netherlands, on which Dividend Distribution Tax (DDT) of ₹2,30,36,643/- was paid at the rate of 16.995% as per the provisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1781/KOL/2024[2013-2014]Status: DisposedITAT Kolkata20 Mar 2026AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

circumstances of the case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case ... assessee had declared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006- 07 to Philips Netherlands, on which Dividend Distribution Tax (DDT) of ₹2,30,36,643/- was paid at the rate of 16.995% as per the provisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1),, KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1780/KOL/2024[2012-2013]Status: DisposedITAT Kolkata20 Mar 2026AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

circumstances of the case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case ... assessee had declared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006- 07 to Philips Netherlands, on which Dividend Distribution Tax (DDT) of ₹2,30,36,643/- was paid at the rate of 16.995% as per the provisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1779/KOL/2024[2011-2012]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-2012

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

circumstances of the case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case ... assessee had\ndeclared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006-\n07 to Philips Netherlands, on which Dividend Distribution Tax (DDT)\nof ₹2,30,36,643/- was paid at the rate of 16.995% as per the\nprovisions of Section 115-O of the Act. The assessee

PHILIPS INDIA LTD.,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1778/KOL/2024[2010-2011]Status: DisposedITAT Kolkata20 Mar 2026AY 2010-2011

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Npage | 2\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

circumstances of the case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case ... assessee had\ndeclared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006-\n07 to Philips Netherlands, on which Dividend Distribution Tax (DDT)\nof ₹2,30,36,643/- was paid at the rate of 16.995% as per the\nprovisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the assessment years i

ITA 1777/KOL/2024[2009-2010]Status: DisposedITAT Kolkata20 Mar 2026AY 2009-2010

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 237Section 244ASection 250

circumstances of the case, the National Faceless Appeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund of excess Dividend Distribution Tax (DDT) paid by the Appellant amounting to Rs. 94,81,687. 2. That on the facts and circumstances of the case ... assessee had declared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006- 07 to Philips Netherlands, on which Dividend Distribution Tax (DDT) of ₹2,30,36,643/- was paid at the rate of 16.995% as per the provisions of section 115-O of the Act. The assessee

PHILIPS INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeals filed by the assessee for all the\n

ITA 1776/KOL/2024[2008-2009]Status: DisposedITAT Kolkata20 Mar 2026AY 2008-2009

Bench: The Tribunal Raising The\Nfollowing Grounds Of Appeal For Ay 2008-09 & More Or Less Similar\Ngrounds Of Appeal Have Been Raised In The Appeals For Other A.Ys. As\Nwell:\Nita No(S). 1776 To 1783/Kol/2024\N Assessment Year(S) 2008-09 To 2015-16\Nphilips India Limited.\N“1. That On The Facts & Circumstances Of The Case, The National Faceless\Nappeal Centre, Delhi [The Ld. Cit(A)] Erred In Rejecting The Claim Of Refund\Nof Excess Dividend Distribution Tax (Ddt) Paid By The Appellant\Namounting To Rs.94,81,687.\N2. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred\Nin Following The Special Bench Decision Of Mumbai Tribunal In The Case Of\Ndcit Vs Tata Oil India Pvt Ltd (Ita No 6997/Mum/2019) Upholding That\Nddt Is A Tax On Profits Of The Domestic Company & Not On The\Nshareholder.\N2.

Section 115Section 244ASection 250

circumstances of the case, the National Faceless\nAppeal Centre, Delhi [the Ld. CIT(A)] erred in rejecting the claim of refund\nof excess Dividend Distribution Tax (DDT) paid by the Appellant\namounting to Rs.94,81,687.\n2. That on the facts and circumstances of the case ... assessee had\ndeclared and paid dividend of ₹13,55,49,560/- pertaining to FY 2006-\n07 to Philips Netherlands, on which Dividend Distribution Tax (DDT)\nof ₹2,30,36,643/- was paid at the rate of 16.995% as per the\nprovisions of Section 115-O of the Act. The assessee

THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED,MUMBAI vs. INCOME TAX CENTRAL CIRCLE 2(1)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is hereby allowed for statistical\npurposes

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm\Nand\Nms. Kavitha Rajagopal, Am\N\Nita No.5274/Mum/2025\N(Assessment Year: 2018-19)\Nm/S. The Bombay Dyeing And\Nmanufacturing Company Limited,\Nneville House, Jn Heredia Marg,\Nballard Estate,\Nmumbai - 400 001\Npan: Aaact2328K\Nvs.\Nnational Faceless Appeal Centre,\Ndelhi (Deputy Commissioner Of\Nincome Tax, Central Circle-2(1)(1),\Nmumbai - 400001\N(Appellant)\N(Respondent)\Nassessee By\N:\Nshri Yogesh Thar, A.R.\Nms. Sukanya Jairam, A.R &\Nshri Saurabh Surana, A.R.\Nrespondent By\N:\Nshri Leyaqat Ali Aafaqui, Sr. Ar\Ndate Of Hearing\N:\N22.12.2025\Ndate Of Pronouncement\N:\N18.03.2025\Norder\Nper Kavitha Rajagopal, J M:\Nthis Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned\Ncommissioner Of Income Tax (Appeals) [‘Ld. Cit(A)' For Short], National Faceless\Nappeal Centre (‘Nfac' For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'),\Npertaining To The Assessment Year (‘A.Y.' For Short) 2018-19.\N2.\Nthe Assessee Has Raised The Following Grounds Of Appeal:\N“1. Ground No. 1: Disallowance Of Rs. 4,65,28,171/- Under Section 14A Of The\Nact:\N1.

Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

scheme, 2019 on the following issues:\nS.No.\nIssues\nClaim of Any Other Amount Allowable as Deduction in Schedule BP\nStock Valuation\nPayment of Dividend Distribution Tax\ni.\nli\nlii\nIv\nV\nDefault in TDS & Disallowance for such Default\nRefund Claim\nVi\nICDS Compliance and Adjustment\nVii\nUnsecured Loans\nViii\nSales

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

account of normal tax and interest payable thereon and remaining 2,09,68,122/- on account of non-payment of Dividend distribution tax (DDT) and interest thereon] which is laced with the following mistakes apparent from records and which are wholly illegal, untenable and erroneous: 1.1 The Ld. DRP/TPO

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

ITA 1782/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 14A(2)

strictly in legal sense, a shareholder has no control and cannot insist on payment of dividend. When declared, it is subjected to dividend distribution tax.\n16. what is also noticeable is that the entire or whole expenditure has been disallowed as if there was no expenditure incurred by the respondent

ACIT, CIRCLE-5(1), HYDERABAD vs. USHODAYA ENTERPRISES PRIVATE LIMITED, HYDERABAD

ITA 1781/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18
Section 143(1)Section 143(2)Section 143(3)Section 14A

strictly in legal\nsense, a shareholder has no control and cannot insist on payment of dividend.\nWhen declared, it is subjected to dividend distribution tax.\n16. what is also noticeable is that the entire or whole expenditure has been\ndisallowed as if there was no expenditure incurred by the respondent

DENSO INTERNATIONAL INDIA PRIVATE LIMITED,DELHI vs. DY. COMMISSIONER OF INCOME TAX, DELHI

In the result, this appeal is partly allowed

ITA 6688/DEL/2025[2019-20]Status: DisposedITAT Delhi13 Mar 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.6688/Del/2025 िनधा"रणवष"/Assessment Year: 2019-20 बनाम Denso International India Private Ld. Dcit, Limited, Vs. Circle 7(1), B-1/D-4, Ground Floor,Mohan C.R. Building, Delhi. Cooperative Estate,Delhi. Pan No.Aabcd1103D अपीलाथ" Appellant ""यथ"/Respondent

Section 115Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

uphold the action of Ld. AO. The second point of dispute was concerning the refund 1 of excess Dividend Distribution Tax (DDT) paid by the assessee, which was claimed as a refund on the basis that the beneficial treaty provisions (India-Japan DTAA) permitted such refund. 1.1 The aggrieved assessee ... erred both in law and on facts in failing to adjudicate the additional ground relating to the claim of excess Dividend Distribution Tax (DDT) paid amounting to Rs.77,24,055/-. 3. The order passed by Ld. CIT(A) and Ld. AO is bad in law and against the facts

METLIFE GLOBAL OPERATIONS SUPPORT CENTER PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 16(1), NEW DELHI

ITA 8750/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Mar 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2018-19] Metlife Global Operations Deputy Commissioner Of Income Support Centre Private Limited. Tax, Circle-16(1), Paharpur Business Centre, Vs C.R. Building, I.P. Estate, 21 Nehru Place, New Delhi-110002 New Delhi-1100019 Pan-Aafcm5000N Appellant Respondent Appellant/Assessee By Shri Rajan Vohra, Adv. & Shri Lekh Mehta, Ca Respondent/Revenue By Shri Shrikant Namdeo, Cit-Dr Date Of Hearing 03.03.2026 Date Of Pronouncement 09.03.2026

Section 115Section 115OSection 143Section 143(3)

upholding the actions of the learned Assessing Officer in not considering and allowing the Appellant's additional claim for refund of excess Dividend Distribution Tax (DDT) paid by it without providing any cogent reasons; Ground of Appeal Nos. 2 and 3: Maintainability of the Appellant's additional claim ... Colorcon Asia Pvt. Ltd. [Tax Appeal No. 5/2024 (Bombay HC)] Page 2 of 5 and thereby ought to have allowed refund of dividend distribution tax in excess of the 10% tax rate to the Appellant; 6. without prejudice to the above, the Appellant prays to the Hon'ble Tribunal

INDIAN CLEARING CORPORATION LTD,MUMBAI vs. THE ADDISSIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 6381/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2018-19 Indian Clearing Corporation Deputy Commissioner Of Ltd., Income Tax, 25Th Floor, P.J. Tower, Vs. Circle-1(2)(1), Dalal Street, Fort, Aayakar Bhavan, Mumbai-400001. Mumbai-400020. Pan : Aabci7140K (Appellant) (Respondent) For Assessee : Shri Niraj Sheth A/W. Ms. Niyati Parikh For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 09-02-2026 Date Of Pronouncement : 18-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Niraj Sheth a/wFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 115Section 143(3)Section 72

learned Commissioner of Income tax (Appeals), NFAC erred in confirming the order of Assessment Officer of not granting credit of Dividend Distribution tax (DDT) paid of Rs.7,37,50,973/- shown in Schedule DDT of ITR 6 and charging of interest of Rs. 1,66,40,041/- u/s.115 ... that there are other grounds relating to setting- off of the brought forward business losses as well as non-grant of credit of Dividend Distribution Tax (DDT) in respect of which there is no finding in the assessment order, however, the same arises out of the computation of income forming

ACIT22(1), MUMBAI vs. SPR ASSOCIATES, MUMBAI

In the result, the appeal filed by the revenue stands dismissed and the cross-objection filed by assessee stands allowed

ITA 6562/MUM/2025[2018]Status: DisposedITAT Mumbai17 Feb 2026

Bench: Smt. Beena Pillai () & Shri Arun Khodpia, ()

Section 147Section 148Section 148ASection 68

receipt as dividend income, ignoring the fact that the mutual fund itself had declared and distributed the amount as dividend and discharged Dividend Distribution Tax thereon. 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in accepting the assessee ... dividend was paid by the mutual fund out of capital funds, without appreciating that once the distribution is made as dividend and Dividend Distribution Tax is paid thereon, the character of the receipt in the hands of the assessee cannot be altered. 6. The appellant craves leave to amend

DSP INVESTMENT MANAGERS PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 3(1)(1), MUMBAI

ITA 3925/MUM/2023[2021-22]Status: DisposedITAT Mumbai13 Feb 2026AY 2021-22
Section 14A

strictly in legal sense, a shareholder has no control and cannot insist\non payment of dividend. When declared, it is subjected to dividend distribution tax.\n16. what is also noticeable is that the entire or whole expenditure has been disallowed as\nif there was no expenditure incurred by the respondent

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. D,C,I.T., CIRCLE - 2, JALPAIGURI, JALPAIGURI

In the result, the appeal filed by the Revenue in ITA No

ITA 975/KOL/2024[2013-2014]Status: DisposedITAT Kolkata11 Feb 2026AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115Section 143(3)Section 250Section 36(1)(viia)Section 40

facts of the case, the Ld. CIT (Appeals)-NFAC, has erred in law and not justified by upholding the imposition of dividend distribution tax of Rs.9,68,963/- under section 115-O of the Income Tax Act, 1961 and interest thereon Rs.4,06,965/- under section ... status of the assessee is to be treated as a Cooperative Society. 8. Ground No. 4 is regarding the imposition of dividend distribution tax amounting to ₹9,68,963/- which is related to Ground No. 3 as on the change of status, the Ld. AO was of the view that

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. D.C.I.T., CIRCLE - 2, JALPAIGURI, JALPAIGURI

ITA 974/KOL/2024[2012-2013]Status: DisposedITAT Kolkata11 Feb 2026AY 2012-2013
Section 115Section 143(3)Section 250Section 36(1)(via)Section 36(1)(viia)Section 40

view that the dividend of\n₹59,72,961/- declared @ 10% to the shareholders from 11.09.2021 was\nliable to be subjected to dividend distribution tax which was levied and\nthe Ld. AO's view has been confirmed by the Ld. CIT(A).\n8.1 The Ld. AR submitted that this issue ... assessee's own case for AY 2015-16 as per\npara 10 of the order which is as under:\n“10. The dividend distribution tax u/s 115-O of the Act and interest u/s\n115P of the Act is applicable only to a domestic company and since the\nassessee

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. JCIT (TDS), RANGE - 6, SILIGURI

ITA 2237/KOL/2024[2013-2014]Status: DisposedITAT Kolkata11 Feb 2026AY 2013-2014
Section 115Section 143(3)Section 250Section 36(1)(via)Section 36(1)(viia)Section 40

view that the dividend of\n₹59,72,961/- declared @ 10% to the shareholders from 11.09.2021 was\nliable to be subjected to dividend distribution tax which was levied and\nthe Ld. AO's view has been confirmed by the Ld. CIT(A).\n8.1 The Ld. AR submitted that this issue ... assessee's own case for AY 2015-16 as per\npara 10 of the order which is as under:\n“10. The dividend distribution tax u/s 115-O of the Act and interest u/s\n115P of the Act is applicable only to a domestic company and since the\nPage

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