https://www.taxtmi.com/caselaws?id=768175 Where the taxpayer's income from aircraft operations in international traffic was shown on the existing record, and by past consistent treatment, to be not chargeable to tax in India under Article 8 of the India-Germany DTAA, a nil withholding tax certificate could not be reduced to a positive rate without cogent reasons or supporting material. The record showed that prescribed information had been furnished and queries answered, while the Revenue did not controvert the treaty-based non-taxability claim. The reduction to 0.10 per cent was therefore unsupported, and the authorities were directed to issue a nil withholding tax certificate, leaving assessment-stage examination of taxability open in accordance with law. en-us Tue, 25 Mar 2025 00:00:00 +0530 Wed, 02 Apr 2025 08:35:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768175 Where the taxpayer's income from aircraft operations in international traffic was shown on the existing record, and by past consistent treatment, to be not chargeable to tax in India under Article 8 of the India-Germany DTAA, a nil withholding tax certificate could not be reduced to a positive rate without cogent reasons or supporting material. The record showed that prescribed information had been furnished and queries answered, while the Revenue did not controvert the treaty-based non-taxability claim. The reduction to 0.10 per cent was therefore unsupported, and the authorities were directed to issue a nil withholding tax certificate, leaving assessment-stage examination of taxability open in accordance with law. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768175