https://www.taxtmi.com/caselaws?id=786563 Where a prior High Court decision establishes taxability between related enterprises, the Competent Authority must adhere to that settled position unless new facts or distinguishing particulars for the relevant assessment period are shown; arbitrary refusal to grant nil-rate withholding relief on the sole ground of a threatened appeal was improper. The statutory scheme requires timely decision-making to prevent undue blockage of an assessee's cash flow where treaty or statutory provisions justify nil or reduced withholding. The impugned refusal and interim 15% certificate were set aside and a nil-rate certificate was directed to be issued within a specified short period. en-us Wed, 04 Feb 2026 00:00:00 +0530 Sat, 14 Feb 2026 08:29:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786563 Where a prior High Court decision establishes taxability between related enterprises, the Competent Authority must adhere to that settled position unless new facts or distinguishing particulars for the relevant assessment period are shown; arbitrary refusal to grant nil-rate withholding relief on the sole ground of a threatened appeal was improper. The statutory scheme requires timely decision-making to prevent undue blockage of an assessee's cash flow where treaty or statutory provisions justify nil or reduced withholding. The impugned refusal and interim 15% certificate were set aside and a nil-rate certificate was directed to be issued within a specified short period. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786563