https://www.taxtmi.com/highlights?id=97406 Petition challenges a Competent Authority withholding certificate applying a treaty-based higher withholding rate to a non-resident US company; the authority failed to apply the settled precedent and did not record reasons for the elevated rate, rendering the certificate unsustainable. The court rejected Revenue submissions that assessment-stage scrutiny justified the certificate, held the absence of proper precedent application and reasoning was decisive, and directed issuance of a reduced treaty-based deduction certificate for the relevant year to mitigate undue withholding while permitting substantive tax scrutiny later. en-us Thu, 05 Mar 2026 08:41:17 +0530 Thu, 05 Mar 2026 08:41:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97406 Petition challenges a Competent Authority withholding certificate applying a treaty-based higher withholding rate to a non-resident US company; the authority failed to apply the settled precedent and did not record reasons for the elevated rate, rendering the certificate unsustainable. The court rejected Revenue submissions that assessment-stage scrutiny justified the certificate, held the absence of proper precedent application and reasoning was decisive, and directed issuance of a reduced treaty-based deduction certificate for the relevant year to mitigate undue withholding while permitting substantive tax scrutiny later. Highlights Income Tax Thu, 05 Mar 2026 08:41:17 +0530 https://www.taxtmi.com/highlights?id=97406