DDT Treaty Dispute as part of India UK DTAA

The Supreme Court, while hearing the Special Leave Petition arising from the Bombay High Court ruling in M/s ColorconAsia Pvt. Ltd., framed substantial questions concerning the nature of Dividend Distribution Tax (DDT), its treaty characterization and applicability of the India-UK Double Taxation Avoidance Agreement. 

The Court also took note of a subsequent Bombay High Court reference doubting the correctness of the earlier ruling and directed circulation of its order to all High Courts, while observing that similar proceedings may be stayed pending adjudication.