Concessional rate to tax the dividend isn't available under treaty if it couldn't be taxed in countr

IT/ILT: Where assessee, a resident of India, received dividend from a Singapore based company in which it owned more than 25 per cent shareholding, in view of para 1 of article 10 of India - Singapore DTAA, amount so received was liable to be taxed at normal rate of 30 per cent