On the application made by the appellant for lower deduction of tax,  the certificate was issued under section 195(2) of the Act, directing payer company, Google Cloud India Pvt Ltd (GCI)  to deduct tax at source at rate of 10 percent at time of making payment to assessee as per provision of section 115A read with DTAA.   The appellant  contended that since it had already subjected to Equalisation Levy of 2 percent on payment, withholding certificate  a double jeopardy.  On writ the Court held that  since the appellant  had already subjected itself to Equalization Levy of 2 per cent on payments under consideration, withholding certificate creates a double jeopardy by asking GCI to withhold tax at rate of 10 per cent, thus, without prejudice to rights and contentions, appellant be permitted to receive remittances, after suffering a withholding of only 8 per cent. Court held that   purely as an interim measure, assessee would be entitled to receive its payment from GCI subject to a deduction of 8 per cent and that deposit of 8 per cent shall not be treated as any non-compliance of impugned order under section 195(2). (AY. 2022-23)