https://www.taxtmi.com/article/detailed?id=17362 Section 197 permits lower or nil tax-deduction certificates where the recipient's total income and applicable domestic law or tax treaty justify that treatment. The officer must apply binding precedent on the same issue and cannot refuse relief merely because the revenue may challenge that precedent. Reconsideration in later years may arise only on materially changed facts, such as a permanent establishment or taxable Indian transactions, after notice and recorded findings. Recipients must make full disclosures and cooperate with enquiries. Administrative systems should enable timely implementation of the applicable legal position without unnecessary fresh applications. en-us Tue, 08 Sep 2026 08:43:12 +0530 Tue, 08 Sep 2026 08:43:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=17362 Section 197 permits lower or nil tax-deduction certificates where the recipient's total income and applicable domestic law or tax treaty justify that treatment. The officer must apply binding precedent on the same issue and cannot refuse relief merely because the revenue may challenge that precedent. Reconsideration in later years may arise only on materially changed facts, such as a permanent establishment or taxable Indian transactions, after notice and recorded findings. Recipients must make full disclosures and cooperate with enquiries. Administrative systems should enable timely implementation of the applicable legal position without unnecessary fresh applications. Articles Income Tax Tue, 08 Sep 2026 08:43:12 +0530 https://www.taxtmi.com/article/detailed?id=17362