https://www.taxtmi.com/caselaws?id=787428 Where payments to a non-resident prima facie are not exigible to tax under the Income tax Act read with the India-USA tax treaty, the Competent Authority must apply the law consistently with binding precedent and consider granting reduced withholding to avoid disproportionate tax deduction while preserving the Revenue's right to assessment and refund. The document directs issuance of a withholding certificate requiring deduction at 2% for assessment year 2026 27 within ten days, limited to that year and without prejudice to the Competent Authority's future lawful scrutiny or applications. en-us Fri, 27 Feb 2026 00:00:00 +0530 Thu, 05 Mar 2026 08:41:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787428 Where payments to a non-resident prima facie are not exigible to tax under the Income tax Act read with the India-USA tax treaty, the Competent Authority must apply the law consistently with binding precedent and consider granting reduced withholding to avoid disproportionate tax deduction while preserving the Revenue's right to assessment and refund. The document directs issuance of a withholding certificate requiring deduction at 2% for assessment year 2026 27 within ten days, limited to that year and without prejudice to the Competent Authority's future lawful scrutiny or applications. Case-Laws Income Tax Fri, 27 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787428