$~78 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 10.02.2026 + W.P.(C) 17641/2025 & CM APPL. 72869/2025 FINANCIAL AND RISK ORGANISATION LIMITED .....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Dr.

Shashwat Bajpai, Adv.

versus THE INCOME TAX OFFICER CIRCLE INT. TAX 1(3)(1) NEW DELHI .....Respondent Through: Mr. Debesh Panda, SSC and Ms.

Anauntta Shankar, Adv.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

JUDGMENT

DINESH MEHTA, J. (ORAL)

1. By way of the present writ petition under Article 226 of the Constitution of India, the petitioner has called in question the order dated 23.06.2025 (passed on 21.08.2025) passed by Circle INT TAX 1(3)(1) (hereinafter referred to as ‘the competent authority’) and consequential certificate dated 21.08.2025 issued under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) whereby the tax withholding certificate (hereinafter referred to as ‘the certificate’) at the rate of 15% has been issued, as against petitioner’s request for issuance of ‘NIL’

rate certificate.

2. As per the pleadings of the petitioner, it is a company incorporated in the United Kingdom and is a tax reside