Certificate under Section 197 for withholding tax rate directed at 2% temporarily, impugned orders set aside

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....Certificate for withholding tax was set aside because the competent authority failed to consider the petitioner's submissions and relied on an AAR decision subsequently overruled by a High Court; accordingly the impugned order and certificate are quashed. The court directed issuance of a withholding tax certificate at 2% (parity with the equalization levy) as an interim measure for the relevant assessment year, to be issued within 15 days. The direction applies only to the specified year; pending appeals before the Tribunal may affect future years and the competent authority must decide subsequent applications in accordance with law.....