JUDGMENT

V. KAMESWAR RAO, J.

1. This petition has been filed challenging an order dated 09.06.2025 and certificate dated 30.07.2025 issued by the respondent/Revenue, whereby the application of the petitioner/assessee under Section 197 read with Section 195 (3) of the Income-tax Act, 1961 (the Act, hereinafter) seeking issuance of a „Nil Withholding Certificate‟ has been rejected.

2. The petitioner is a company incorporated under the laws of the United Kingdom, and is engaged in the business of providing international education across the globe. The petitioner has a subsidiary in India, Nord Anglia Education India Pvt. Ltd. (Nord India, hereinafter), to which the petitioner extends routine management and administrative support services, including marketing and communication, human resources, finance, IT, and corporate development, which are subsequently recovered on a strict cost-to-cost basis without any markup.

3. According to Dr. Shashwat Bajpai, learned counsel for the petitioner, the services rendered by the petitioner are purely managerial in nature and do not partake the character of Fees for Technical Services (FTS) under Section 9(1)(vii) of the Act. More importantly, under Ar