Pursuant to the orders passed by the  court, the judgment debtor deposited a cumulative sum of Rs. 4.50 crores, a part of which was released vide order dated 17.12.2018. The decree holder, presently, seeks release of the balance amount along with accrued interest. The reason that a certain portion of the amount was kept back was to ascertain the view of the income tax department as to whether the decree holder could be called upon to pay withholding tax. The income tax department has treated monies received under the award towards arbitration costs and legal costs as income of the decree holder and thereby proceeded to take the stand that the same will be taxable as “fee for technical services”, both under the provisions of  the Act, and the DTAA.  Court held that once a claim merges into a decree of the Court it transcends into a judgment-debt and, therefore, only those adjustments and deductions can be made which are permissible under the Code of Civil Procedure, 1908. The judgments encapsulate the theme that a decree should be executed according to its tenor unless modified by a statute such as the 1962 Act. Accordingly the Court directed the , the Registry to release the balance amount available with it along with accrued interest to the decree holder without deducting any sum towards withholding tax. Followed  (i) All India Reporter v. Ramachandra D. Datar, (1961 41 ITR 446 (SC)/ (1961) 2 SCR 773, V.K. Dewan v. DDA, Execution Petition No. 194/2005, Delhi High Court.  Sino Ocean Limited v. Saivi Chemical Industries Limite, Chamber Summons No. 76/2013 in Execution Application (Lodg.) No. 263/2012, American Home Products Corporation v. MAC Laboratories Pvt. Ltd. and Am., (1986) 1 SCC 465. , Islamic Investment Company v. Union of India (UOI) and Anr., 2002 (4) BOMCR 685 ,  S.S. Miranda Ltd. v. Shyam Bahadur Singh, (1985) 154 ITR 849  (Cal) (HC) ( Exp . 334 of 2014 dt 31-07 -2019 )