Section 197 Certificate: Lower Tax Rate Deduction Not Applicable to Specified Amounts; Interest u/s 201(1A) Unjustified.

Deduction of tax at a lower rate - It is therefore clear in the statutory provision of deduction of tax at source at lower rate is “person specific” and cannot be extended to the amounts specified by the recipient of the payment while making an application for grant of certificate u/s 197 - Levy of interest u/s 201(1A) cannot be sustained - AT .....

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