$~241 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of decision: 4^th February, 2026.

+ W.P.(C) 15023/2025 & CM APPL. 61867/2025 GODADDY.COM LLC .....Petitioner Through: Mr. Sachit Jolly, Sr. Advocate with Mr. Mayank Chaturvedi and Mr.

Abhyudaya Shankar, Advocates.

versus ASSISTANT/DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(3)(1), INTERNATIONAL TAXATION DELHI .....Respondents Through: Mr. Siddhartha Sinha, SSC with Ms.

Easha Gurung, JSC.

CORAM:

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

J U D G M E N T

DINESH MEHTA, J. (Oral

1. By way of present writ petition, the petitioner has challenged the order dated 06.03.2025 (wrongly dated) so also the consequential certificate dated 21.08.2025 passed/issued by respondent No.1 (hereinafter referred to as ‘Competent Authority’) under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’).

2. As per the petitioner, it is engaged in the business of providing domain name services, including domain name registration, web hosting, web designing, SSL certification, etc.

3. Mr. Sachit Jolly, learned Senior Counsel submitted that the petitioner had not only succeeded in its appeal before the Income Tax A