Authorities to Re-evaluate Tax Chargeability for Sum Under Distributor Agreement, Section 197 NIL Rate Certificate Sought.

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....Application u/s 197 - reduction of withholding tax - petitioner had sought a certificate, at “NIL” rate of tax - request to issue certificate at lower was rejected - Reduction of withholding tax u/s 195 is the rule, it is required to be borne in mind, that deduction of withholding tax morphs into an obligation, only if the sum received is chargeable to tax. The petitioner’s entire case is, that the sum that it receives under the Distributor Agreement is not chargeable to tax. - Authorities directed to re-examine the issue - HC....