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2021 (3) TMI 331 - HC - Income TaxRate of tax deduction certificate under Section 197 - Tax deduction certificates qua offshore supply contracts were issued at the rate of 1.72% - For offshore supplies, the rate of withholding tax has been enhanced to 10% - in the earlier years, the assessee was contesting the stand of the revenue that it had the Permanent Establishment (in short ‘PE’) in India - HELD THAT:- We direct that, for the moment, the concerned officer will issue a Tax deductor certificate under Section 197 of the Act for the FY 2020-2021 (Assessment Year 2021-2022) in line with the rate applied for FY 2018-2019 and FY 2019-2020. Assessee will file an affidavit within 10 days from today which will inter alia indicate that in case it were to, ultimately, fail in the captioned writ petition, it will deposit the deficit amount within four weeks of such a direction being issued by the Court. List the captioned writ petition on 16.04.2021.
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