2021 (3) TMI 331

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....AJIV SHAKDHER AND HON'BLE MR. JUSTICE TALWANT SINGH Petitioner Through: Mr. Percy Pardiwalla, Sr. Adv. With Ms. Tanmayee Rajkumar, Adv. Respondents Through: Mr. Sunil Kumar Agarwal, Adv. O R D E R [Court hearing convened via video-conferencing on account of COVID-19] CM No.8444/2021 in W.P.(C) 2802/2021 CM No.8446/2021 in W.P.(C) 2803/2021 CM No.8466/2021 in W.P.(C) 2805/2....

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....s were issued at the rate of 1.72%. 4.1. Mr. Pardiwalla says that despite the aforementioned position, via the impugned order, vis-a-vis offshore supplies, the rate of withholding tax has been enhanced to 10%. 4.2. According to Mr. Pardiwalla, in the earlier years, the assessee was contesting the stand of the revenue that it had the Permanent Establishment (in short 'PE') in India. This posi....

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....d be deposited by the petitioner within four weeks of such order being issued by the Court. 5. We may record that Mr. Sunil Kumar Agarwal, who appears on behalf of the respondents-revenue, has submitted that there has been a change in the circumstances in F.Y. 2020-2021 and, therefore, no interference, at this stage, is called for qua the impugned order. 5.1 Furthermore, Mr. Agarwal also sub....