* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 02.12.2025 Judgment delivered on: 16.03.2026 Judgment uploaded on: As per Digital Signature~

+ W.P.(C) 11956/2025 & CM APPL. 65195/2025 MAKE MYTRIP (INDIA) PRIVATE LIMITED .....Petitioner versus ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-75(1), DELHI & ANR. .....Respondents Advocates who appeared in this case For the petitioner : Mr. Salil Kapoor, Ms. Soumya Singh, Mr. Sumit Lalchandani and Ms Ananya Kapoor, Advocates For the Respondents : Mr. Siddhartha Sinha, SSC.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR

JUDGMENT

V. KAMESWAR RAO, J.

1. The present petition has been filed challenging the order dated 17.07.2025 passed by the respondent no. 2 i.e., Deputy Commissioner of Income Tax (TDS), Gurugram for Financial Year (“F.Y.”) 2025-26, relevant to Assessment Year (“A.Y.”) 2026-27, whereby the respondent no.2 has rejected an application under Section 197 of the Income Tax Act, 1961 (“the Act”) dated 19.05.2025 seeking a „NIL Withholding Certificate‟ under Section 197 of the Act or without prejudice, a certificate at the rate of 0.30%, consistent with the certificates which were issued by t