SFDC IRELAND LIMITED vs COMMISSIONER OF INCOME TAX & ANR.

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 17.02.2025 W.P.(C) 12847/2024 and CM APPL. 53630/2024 SFDC IRELAND LIMITED ..... Petitioner versus COMMISSIONER OF INCOME TAX & ANOTHER ... Respondents Advocates who appeared in this case: For the Petitioner : Mr Ajay Vohra, Senior Advocate with Mr Aniket D Agarwal and Mr Samarth Chaudhari, Advocates. For the Respondent : Mr Sunil Aggarwal, Senior Standing Counsel, Mr Shivansh B Panday, Ms Priya Sarka, Mr Viplav Acharya, JSCs and Mr Utkarsh Tiwari, Advocates. CORAM HON’BLE MR JUSTICE VIBHU BAKHRU HON’BLE MR JUSTICE TUSHAR RAO GEDELA JUDGMENT VIBHU BAKHRU, J. 1. The petitioner has filed the present petition, inter alia, impugning an order dated 09.07.2024 (hereafter the impugned order) passed by respondent no.2 under Section 197 of the Income Tax Act, 1961 (hereafter the Act) in respect of the Financial Year (FY) 2024-25 relevant to the Assessment Year (AY) 2025-26 authorizing the petitioner to receive the payment (estimated at ₹6,33,34,44,669/-) from 2. The petitioner also impugns the certificate dated 09.07.2024 (hereafter the impugned certificate) issued under Section 197 of the Act authorising SFDC India to make pa