Section 195 & 197 of the Income Tax Act, 1961– TDS– AO was justified in granting certificate of deduction @ 4 percent of gross receipts as AO while exercising power under section 197 during the course of the enquiry cannot undertake an exhaustive exercise to determine the issue of PE conclusively ; further, there cannot be any dispute that existence of PE is required to be determined by law for each year separately on the basis of the scope, determination of PE was against the assessee – National Petroleum Construction Company vs. Deputy Commissioner of income tax [2020] 312 CTR (Delhi) 217