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of Orders/certificates u/s 197 - rate of withholding tax - he petitioner, who is a non-resident and does not have a PE in India, claims that the subject income is “business income.” It is because of these varying stands, that a dispute arose with regard to the rate at which withholding tax had to be pegged. - the rate of withholding tax, for the moment, will be pegged at 4%. The respondents/revenue will issue a certificate u/s 197 as expeditiously as possible - HC
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