2021 (6) TMI 1117

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..... DELHI HIGH COURT ] Accordingly, the impugned orders dated January 4, 2021 and March 11, 2021 are set aside. The writ petition is disposed of in the aforesaid terms. Consequently, a certificate under section 197 will be issued in favour of the petitioner, indicating therein, that the rate of tax, on dividend, as applicable qua the petitioner is 5 per cent. under the India-Swiss Double Taxatio .....

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