Revenue Cannot Ignore Tribunal Findings While Issuing Section 197 Certificate: Delhi HC

Financial And Risk Organisation Limited Vs ITO (Delhi High Court)

The petitioner filed a writ petition under Article 226 challenging the order dated 23.06.2025 (passed on 21.08.2025) and the consequential certificate dated 21.08.2025 issued under Section 197 of the Income Tax Act, 1961, whereby a tax withholding certificate at the rate of 15% was granted instead of the ‘NIL’ rate sought.

The petitioner, a United Kingdom incorporated company and tax resident of the UK for AY 2026–27, provides subscription-based information and software products, including access to fina

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