S. 197 : Deduction at source-Certificate for a lower rate-Payments to Non-Resident-Fees for technical services-No article contained in double taxation avoidance agreement-Department directed to issue a certificate at withholding rate of four Per Cent-Contentions of parties left open-DTAA-India-UAE. [Art. 226]
WTS Energy DMCC v. Dy. CIT (2023) 451 ITR 175 (Delhi)(HC)