Delhi HC Quashes 10% TDS Order, Directs Nil Withholding Certificate for Foreign Company Lacking PE in India

SFDC Ireland Limited Vs CIT (Delhi High Court)

The Delhi High Court examined a writ petition challenging an order dated 26 September 2025 and a corresponding certificate dated 11 September 2025 issued under Section 197 of the Income Tax Act, 1961, which required deduction of tax at source at 10% on payments made to the petitioner. The petitioner, a company incorporated and tax resident in Ireland, is engaged in providing standardized, cloud-based customer relationship management platforms through a reseller in India. It asserted that it had no place of business, employees, or perma

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