Section 197 Certificate Quashed Because DAPE Finding Was Overturned

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...