Certificate u/s 197 - Deduction of TDS are low rate or NIL rate - India Switzerland DTAA read with the...

Certificate u/s 197 - Deduction of TDS are low rate or NIL rate - India Switzerland DTAA read with the protocol and Most Favoured Nation (“MFN”) clause - no separate notification is required insofar as the applicability of the protocol is concerned and the same forms an integral part of the Convention - order of higher appellate authorities should be followed ‘unreservedly’ and mere fact that decision is not acceptable to the Revenue cannot be a ground for not following the decision of higher authority. - HC .....

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