* IN THE HIGH COURT OF DELHI AT NEW DELHI

% Judgment Reserved on: 17.10.2025

Judgment delivered on: 23.12.2025

Judgment uploaded on: As per Digital Signature~

+ W.P.(C) 10556/2025 & CM APPL. 43739/2025 (stay)

ZSCALER INC ..... PETITIONER

versus

DEPUTY COMMISSIONER OF INCOME TAX,

CIRCLE 3(1)(1), NEW DELHI .... RESPONDENT

Advocates who appeared in this case

For the Petitioner : Mr. Kamal Sawhney, Mr. Arun Bhadauria

and Mr. Puru Medhira, Advocates.

For the Respondent : Mr. Sunil Agarwal, SSC, Mr. Viplav

Acharya, JSC, Ms. Priya Sarkar, JSC with Mr. Anugrah Dwivedi and Mr. Utkarsh

Tiwari, Advocates

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO

HON'BLE MR. JUSTICE VINOD KUMAR

JUDGMENT

V. KAMESWAR RAO, J.

1. This petition has been filed seeking to set aside a certificate issued under Section 197 of the Income Tax Act, 1961 (the Act) dated 06.05.2025 along with an order dated 07.05.2025 read with continuation order dated 16.05.2025, dismissing the petitioner’s application for issuance of ‘Nil

Withholding Certificate’ for prospective payments amounting to Rs.13,19,12,77,703/-.

2. The petitioner is a company incorporated under the laws of the United State of America (USA) and a non-resident entity, in the business