Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
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Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days.
Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days.
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