9911796707
TMI Blog2021 (3) TMI 331X X X X Extracts X X X X X X X X Extracts X X X X ..... USTICE 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) 2805/2021 1. Allowed, subject to just exceptions. W ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 position, even according to Mr. Pardiwalla, has changed as the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing 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 submits that, at the stage of issuance of certificate under Section 197 of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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