DDT rate as per section.115-O

I think DDA will not be applicable  to dividend distribution Tax because it is not decuted from the dividend but it is paid by the dividen declaring Company so it is a Company's responsibility and liability.

1. According to sec 115-O dividend declared by the domestic company will be taxable @ 15%. 
2. But DDT is paid on grossed-up amount which effectively comes to 17.647 % (15%/85%) which is nothing but the grossed-up amount on the above 15%. 
3. Adding up surcharge @ 12% and education cess @ 4%, the effective final rate of dividend that needs to be applied to the amount distributed to the shareholder comes to 20.56%. 
4. From the introduction of grossing up the concept on dividend this confusion exists. Otherwise its a straight forward computation just like other taxes. 
Please correct me if the above solution has an alternative view.