https://www.taxtmi.com/caselaws?id=791132 An application for a NIL withholding tax certificate under section 197 was rejected on the basis that cross charges paid by associated enterprises were taxable as fees for technical services and fees for included services. The High Court set aside the rejection and held that the taxpayer was entitled to a NIL withholding tax certificate for the cross-cost charges, while leaving the Revenue free to examine the taxability of the receipts in regular assessment proceedings. The Supreme Court declined to interfere and dismissed the special leave petition. en-us Mon, 04 May 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791132 An application for a NIL withholding tax certificate under section 197 was rejected on the basis that cross charges paid by associated enterprises were taxable as fees for technical services and fees for included services. The High Court set aside the rejection and held that the taxpayer was entitled to a NIL withholding tax certificate for the cross-cost charges, while leaving the Revenue free to examine the taxability of the receipts in regular assessment proceedings. The Supreme Court declined to interfere and dismissed the special leave petition. Case-Laws Income Tax Mon, 04 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791132