https://www.taxtmi.com/caselaws?id=787483 Nil deduction certificate under Section 197 was required for AY 2026-27 because the factual matrix matched prior years where nil certificates were issued, earlier attribution of revenue to the Indian permanent establishment was held absorbed by remuneration to Indian distributors, and no change in business model or facts justified a 10% certificate. The 10% certificate predated a later demand and therefore could not be sustained; respondents are directed to issue a nil rate certificate and given procedural directions if a contrary taxable PE finding is to be recorded after notice. en-us Fri, 27 Feb 2026 00:00:00 +0530 Fri, 06 Mar 2026 08:30:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787483 Nil deduction certificate under Section 197 was required for AY 2026-27 because the factual matrix matched prior years where nil certificates were issued, earlier attribution of revenue to the Indian permanent establishment was held absorbed by remuneration to Indian distributors, and no change in business model or facts justified a 10% certificate. The 10% certificate predated a later demand and therefore could not be sustained; respondents are directed to issue a nil rate certificate and given procedural directions if a contrary taxable PE finding is to be recorded after notice. Case-Laws Income Tax Fri, 27 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787483