The assessee contended that dividend distribution tax was payable at the rate prescribed under the applicable Double Taxation Avoidance Agreement as the dividend was distributed to non-resident shareholders. The Tribunal held that dividend distribution tax is a liability of the domestic company under section 115-O and is payable at the rate prescribed therein. The concessional rate available to a non-resident shareholder under the applicable DTAA could not be extended to the domestic company unless the treaty specifically so provided. (AY. 2018-19).