2025 (1) TMI 659

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..... HIGH COURT] a certificate u/s 197 of the Act will be issued in favour of the Petitioner, indicating therein, that the rate of tax, on dividend, as applicable qua the Petitioner is 5% under India-Netherlands DTAA - HELD THAT:- The writ petition filed by the respondent was allowed by the High Court by relying upon a decision of Concentrix Services Netherlands B.V.[ 2021 (4) TMI 1051 - DELHI HIGH COU .....

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..... AOR Mr. Ashish Sarda , Adv ORDER 1. Leave granted. 2. The writ petition filed by the respondent was allowed by the High Court by relying upon a decision of the same High Court (Delhi High Court) in the case of Concentrix Services Netherlands B.V. vs. ITO (TDS), W.P. (C) 9051/2020 [2021] 127 taxmann.com 43 (Delhi) and Nestle SA vs. Assessing Officer, Circle (International Taxation), W.P. (C) No.324 .....

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