$~7 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 975/2026, CM APPL. 4721/2026, CM APPL. 4722/2026 &

CM APPL. 4723/2026 EMERALD PUBLISHING LIMITED .....Petitioner Through: Ms. Sonu Bhatnagar, Sr. Adv.

versus DEPUTY CORNMISSIONER OF INCOME TAX.....Respondent Through: Mr. Debesh Panda, SSC and Adv.

Anauntta Shankar, Adv.

CORAM:

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

O R D E R

% 03.02.2026

1. The instant writ petition impugns the order dated 08.11.2025 passed by the office of Circle Int Tax 1(2)(2) (hereinafter referred to as competent authority) and certificate dated 08.11.2025 issued under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) whereby a tax withholding certificate at the rate of 15% has been issued to the petitioner against its request of certificate of nil deduction.

2. As per the facts pleaded, the petitioner Emerald Publishing Limited ('the Assessee' or 'Company') an entity incorporated under the laws of United Kingdom ('UK') is a tax resident of the UK. The Company is engaged in publication of academic journals and books (in the area of business and management including social sciences, engineering, linguis