https://www.taxtmi.com/caselaws?id=788914 A nil withholding tax certificate under Section 197 had to be assessed on the basis of the assessee's existing and estimated tax liability under Rule 28AA. The Court held that, where the same income had already been found taxable in India in earlier years and those findings remained undisturbed, the Assessing Officer could not issue a nil deduction certificate contrary to that subsisting position. It also rejected the argument that services rendered through email, conference calls or video conferencing changed the tax consequence for this purpose. The rejection of the nil withholding tax certificate was upheld. en-us Fri, 27 Mar 2026 00:00:00 +0530 Tue, 31 Mar 2026 08:27:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788914 A nil withholding tax certificate under Section 197 had to be assessed on the basis of the assessee's existing and estimated tax liability under Rule 28AA. The Court held that, where the same income had already been found taxable in India in earlier years and those findings remained undisturbed, the Assessing Officer could not issue a nil deduction certificate contrary to that subsisting position. It also rejected the argument that services rendered through email, conference calls or video conferencing changed the tax consequence for this purpose. The rejection of the nil withholding tax certificate was upheld. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788914