https://www.taxtmi.com/caselaws?id=786945 A taxpayer was found entitled to a nil withholding certificate for Matching solution services under section 197 because, on a prima facie review of the agreements and legal position, the receipts were not chargeable to tax in India and did not constitute fees for included services under Article 12(4) of the India-US DTAA. The competent authority was held to have no sustainable basis to deny nil rate for that component, and the denial was set aside to that extent. en-us Tue, 17 Feb 2026 00:00:00 +0530 Mon, 23 Feb 2026 07:38:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786945 A taxpayer was found entitled to a nil withholding certificate for Matching solution services under section 197 because, on a prima facie review of the agreements and legal position, the receipts were not chargeable to tax in India and did not constitute fees for included services under Article 12(4) of the India-US DTAA. The competent authority was held to have no sustainable basis to deny nil rate for that component, and the denial was set aside to that extent. Case-Laws Income Tax Tue, 17 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786945