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2021 (10) TMI 1212 - HC - Income TaxCertificate for deduction at lower rate u/s 197 - India Netherlands DTAA read with the Protocol and MFN clause - HELD THAT:- Issue notice. Mr.Ruchir Bhatia, Advocate accepts notice on behalf of the Respondents. He admits that the issue raised in the present writ petition is squarely covered in CONCENTRIX SERVICES NETHERLANDS B.V. OPTUM GLOBAL SOLUTIONS INTERNATIONAL BV [2021 (4) TMI 1051 - DELHI HIGH COURT] - Accordingly, the impugned order and certificate are set aside. Consequently, a certificate u/s 197 of the Act will be issued in favour of the Petitioner, indicating therein, that the rate of tax, on dividend, as applicable qua the Petitioner is 5% under India-Netherlands DTAA.
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