Delhi HC judgment regarding Nil Withholding Certificates under Section 197

Nord Anglia Education Limited Vs DCIT (Delhi High Court) Nil -Withholding Certificates under Section 197 of the Income-tax Act: Statutory Discipline, Treaty Interpretation and Judicial Control over Revenue Discretion The scheme of tax deduction at source in respect of payments to non-residents is anchored in the principle that tax can be withheld only when the underlying income is chargeable to tax in India. Section 195 of the Income-tax Act, 1961 gives statutory recognition to this principle, while Section 197 acts as a statutory safeguard against excessive or unwarranted withholding. The ...