India-Italy DTAA Not Applicable When Domestic Company Pays DDT u/s 115O of Income Tax Act: ITAT [Read Order]

India-Italy DTAA does not apply when a domestic company pays DDT under Section 115O of the Income Tax Act
TAA - Income Tax Act - DDT - ITAT - Dividend Distribution Tax - Section 115O of the Income Tax Act - Income Tax Appellate Tribunal - Taxscan

The Pune bench of the Income Tax Appellate Tribunal (ITAT) ruled that the India-Italy Double Taxation Avoidance Agreement (DTAA) is not applicable when a domestic company pays Dividend Distribution Tax (DDT) under Section 115O of the Income Tax Act, 1961. The assessee, Piaggio Vehicles Private Limited, a domestic company, is engaged in the manufacture and…

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