2021 (6) TMI 1117 - HC - Income Tax

TDS u/s 195 - India-Swiss DTAA - HELD THAT - Respondent-Revenue cannot but accept that the issue raised in the present petition is covered by the judgment of this court dated April 22 2021 passed in Concentrix Services Netherlands B. V. 2021 (4) TMI 1051 - 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 Taxation Avoidance Agreement.

Summary

The High Court Delhi High Court judgment in 2021 (6) TMI 1117 stated that the impugned orders dated January 4, 2021 and March 11, 2021 are set aside. A certificate under section 197 of the Income-tax Act, 1961 will be issued in favor of the petitioner, indicating a 5% tax rate on dividends under the India-Swiss Double Taxation Avoidance Agreement.