https://www.taxtmi.com/caselaws?id=786667 Application for a NIL-rate withholding certificate under the Income-tax Act was held to require the competent authority to follow the Income Tax Appellate Tribunal's conclusive findings on substantially similar facts that the payments were not royalty and not taxable through a permanent establishment; the authority cannot rely on an assessment order already set aside without recording material distinctions after notice and opportunity. The impugned order and certificate were set aside and a NIL-rate certificate was directed to be issued for AY 2026-27, with directions to continue issuing NIL certificates for subsequent years unless a recorded finding of taxable transactions or permanent establishment is made following notice. en-us Tue, 10 Feb 2026 00:00:00 +0530 Tue, 17 Feb 2026 07:29:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786667 Application for a NIL-rate withholding certificate under the Income-tax Act was held to require the competent authority to follow the Income Tax Appellate Tribunal's conclusive findings on substantially similar facts that the payments were not royalty and not taxable through a permanent establishment; the authority cannot rely on an assessment order already set aside without recording material distinctions after notice and opportunity. The impugned order and certificate were set aside and a NIL-rate certificate was directed to be issued for AY 2026-27, with directions to continue issuing NIL certificates for subsequent years unless a recorded finding of taxable transactions or permanent establishment is made following notice. Case-Laws Income Tax Tue, 10 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786667