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10. [2025] 175 taxmann.com 707 (Mumbai - Trib.)
Polycab India Ltd. vs. ACIT
IT APPEAL NOS. 4671 AND 4672 (MUM.) OF 2023 A.Y.: 2018-19 to 2021-22
Dated: 16.06.2025
Section 115O
DDT cannot be charged on dividend paid to a shareholder who is granted immunity from taxation
FACTS
The assessee, a listed Indian company, had paid dividends to its shareholders, which included International Finance Corporation (“IFC”), a World Bank Group entity. In terms of International Finance Corporation (“IFC”) Act, 1958, IFC was exempted from all taxation on its assets, income, property, and operations. The assessee had discharged Dividend Distribution Tax (“DDT”) under Section 115-O of the Act on entire dividend paid by it. The Assessee applied for refund of DDT under Section 237 in respect of DDT relatable to IFC.
The AO rejected the application on the footing that if the argument of the Assessee were accepted, then dividend payable to every entity which was exempt was liable to be excluded from DDT. However, no such provision is envisaged unde
