https://www.taxtmi.com/caselaws?id=786944 A Section 197 certificate must be based on accurate facts and a rational view of taxable income; where the asserted outstanding demand on the ITBA portal was incorrect, the foundation for fixing deduction at 0.1% failed. The court found that airline operation income was not presently exigible to tax under the India-UK treaty read with Section 90, while taxable ancillary services were already being taxed. Earlier NIL certificates, including for part of the same financial year, reinforced that the departure lacked basis. The impugned order was quashed and a NIL-rate certificate was directed. en-us Tue, 17 Feb 2026 00:00:00 +0530 Mon, 23 Feb 2026 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786944 A Section 197 certificate must be based on accurate facts and a rational view of taxable income; where the asserted outstanding demand on the ITBA portal was incorrect, the foundation for fixing deduction at 0.1% failed. The court found that airline operation income was not presently exigible to tax under the India-UK treaty read with Section 90, while taxable ancillary services were already being taxed. Earlier NIL certificates, including for part of the same financial year, reinforced that the departure lacked basis. The impugned order was quashed and a NIL-rate certificate was directed. Case-Laws Income Tax Tue, 17 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786944