https://www.taxtmi.com/caselaws?id=787097 Challenge to a withholding tax certificate issued under Section 197 concerning SaaS/licence based supplies was framed around whether higher withholding was justified absent adjudication by an assessing authority. The material showed a prima facie arguable case that higher withholding may not apply; the competent authority's exercise of discretion warranted an intermediate withholding pending regular assessment. The impugned certificate was quashed and a fresh certificate was directed fixing reduced withholding within a short timeframe, with future Section 197 applications to be decided within a prescribed 30 day period to prevent undue delay. en-us Tue, 17 Feb 2026 00:00:00 +0530 Thu, 26 Feb 2026 07:35:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787097 Challenge to a withholding tax certificate issued under Section 197 concerning SaaS/licence based supplies was framed around whether higher withholding was justified absent adjudication by an assessing authority. The material showed a prima facie arguable case that higher withholding may not apply; the competent authority's exercise of discretion warranted an intermediate withholding pending regular assessment. The impugned certificate was quashed and a fresh certificate was directed fixing reduced withholding within a short timeframe, with future Section 197 applications to be decided within a prescribed 30 day period to prevent undue delay. Case-Laws Income Tax Tue, 17 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787097