$~85 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of decision: 24^th February, 2026 + W.P.(C) 1334/2026 CM APPL. 6504-6505/2026 DOCUSIGN INC. .....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Dr.

Shashwat Bajpai & Mr. Mayank Chaturvedi, Adv.

versus THE INCOME TAX OFFICER, WARD INT. TAX 1(2)(2), CIVIC CENTRE NEW DELHI .....Respondent Through: Mr. Puneet Rai, SSC 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 11.08.2025 (mentioned as 15.04.2025), passed by the Office of Circle Int Tax 1(2)(2) (hereinafter referred to as the ‘Competent Authority’) so also the certificate dated 11.08.2025, whereby the competent authority has issued a tax withholding certificate at the rate of 4% under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’).

2. As per the petitioner, it is a non-resident company and a tax resident of the United States of America (for short ‘USA’), with its principal place of business at San Francisco, California, USA. It is a software company that provides solutions for managing electronic agre