https://www.taxtmi.com/caselaws?id=425802 The Supreme Court upheld the High Court's decision, dismissing the appeal and affirming the justification for issuing the certificate under Section 197 based on the Appellant's request. It was reiterated that the determination of Permanent Establishment (PE) and taxability of income from activities outside India should be evaluated annually, with no application of the principle of res judicata in tax proceedings. The Appellant's request for a 4% TDS rate prevented it from challenging the certificate, despite a dissenting opinion stressing the importance of consistency and proper procedure in issuing such certificates. en-us Fri, 29 Jul 2022 00:00:00 +0530 Wed, 10 Jun 2026 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=425802 The Supreme Court upheld the High Court's decision, dismissing the appeal and affirming the justification for issuing the certificate under Section 197 based on the Appellant's request. It was reiterated that the determination of Permanent Establishment (PE) and taxability of income from activities outside India should be evaluated annually, with no application of the principle of res judicata in tax proceedings. The Appellant's request for a 4% TDS rate prevented it from challenging the certificate, despite a dissenting opinion stressing the importance of consistency and proper procedure in issuing such certificates. Case-Laws Income Tax Fri, 29 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=425802