Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)
section 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 with reference to such dividend income. Nevertheless, we are conscious of the sovereign's prerogative to extend the treaty protection to domestic companies paying dividend distribution tax through the mechanism of DTAAs. Thus, wherever