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Section 197 Certificate Quashed Because DAPE Finding Was Overturned
Case Law Details
- Case Name
- Zscaler Inc. Vs DCIT (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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Zscaler Inc. Vs DCIT (Delhi High Court)
Section 197 Certificate Can’t Survive Once DAPE Finding Is Set Aside: Delhi HC Quashes 8.75% TDS on Zscaler
Delhi High Court, in Zscaler Inc. vs DCIT (W.P.(C) No. 10556/2025, judgment dated 23.12.2025), set aside the certificate and orders issued u/s 197 directing deduction of tax at 8.75% on payments aggregating to ₹1,319 crore for FY 2025-26. The Assessing Officer had rejected the application for Nil/Lower Withholding Certificate solely on the basis of assessment orders for AYs 2021-22 and 2022-23, holding that Zscaler’s Indian subsidiary constit...
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