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TMI Blog2021 (8) TMI 1274X X X X Extracts X X X X X X X X Extracts X X X X ..... s under the Income-tax Act, 1961 / India-USA Double Taxation Avoidance Agreement (DTAA) rather than business income ? - HELD THAT:- Issue notice. Mr.Ruchir Bhatia, Advocate accepts notice. He prays for and is granted six weeks time to file the counter affidavit. Rejoinder affidavit, if any, be filed before the next date of hearing. Since the petitioner has prayed for refund of taxes and this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... revision of certificate dated 07th June 2021 issued under section 197 of the Act by which the Respondent No 2 had directed the Indian Customers to deduct tax at the rate of 10% (excluding surcharge and cess as applicable) at the time of payment to the Petitioner. Petitioner also challenges certificate under section 197 of the Income Tax Act, 1961 dated 07th June 2021 issued by the Respondent No 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 164(ca) of Finance Act, 2016 without any permanent establishment in India, for providing subscription based interactive website access for online data analytics to Indian Customers? (b) Whether the Respondents erred in law and on facts in re-characterizing the nature of payments to be received by the Petitioner from Indian Customers as Fee for Technical/Included Services under the In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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