https://www.taxtmi.com/caselaws?id=239252 A nil withholding certificate under Section 197 was held available where the taxpayer had invoked the mutual agreement procedure under the treaty, furnished a bank guarantee, and sought deferment of tax collection under the governing memorandum. The refusal to grant relief on the ground that the benefit arose only after formal admission of the matter, or that expiry of the assessment year made the request infructuous, was found inconsistent with Article 27 and the memorandum. Those instruments contemplated suspension of collection for prior, current, and future taxable years once the procedure was invoked and revenue was secured, so later admission could not defeat entitlement to consideration of the certificate. en-us Fri, 25 Oct 2013 00:00:00 +0530 Mon, 03 Feb 2014 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239252 A nil withholding certificate under Section 197 was held available where the taxpayer had invoked the mutual agreement procedure under the treaty, furnished a bank guarantee, and sought deferment of tax collection under the governing memorandum. The refusal to grant relief on the ground that the benefit arose only after formal admission of the matter, or that expiry of the assessment year made the request infructuous, was found inconsistent with Article 27 and the memorandum. Those instruments contemplated suspension of collection for prior, current, and future taxable years once the procedure was invoked and revenue was secured, so later admission could not defeat entitlement to consideration of the certificate. Case-Laws Income Tax Fri, 25 Oct 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239252