The assessee has filed revision application on the ground that beneficial rate of 5 per cent prescribed under article 10(2) of the India-Mauritius DTAA shall prevail over the DDT rate of 15 percent as provided under section 115-O of the Act. Commissioner dismissed the application without giving any reasons. On writ the matter was remanded back to the PCIT for passing speaking order. (AY. 2018-2019)