FINANCIAL AND RISK ORGANISATION LIMITED vs THE INCOME TAX OFFICER CIRCLE INT. TAX 1(3)(1) NEW DELHI

Judgment text excerpt

$~78 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 10.02.2026 + W.P.(C) 17641/2025 & CM APPL. 72869/2025 FINANCIAL AND RISK ORGANISATION LIMITED .....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Dr. Shashwat Bajpai, Adv. versus THE INCOME TAX OFFICER CIRCLE INT. TAX 1(3)(1) NEW DELHI .....Respondent Through: Mr. Debesh Panda, SSC and Ms. Anauntta Shankar, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (ORAL) 1. By way of the present writ petition under Article 226 of the Constitution of India, the petitioner has called in question the order dated 23.06.2025 (passed on 21.08.2025) passed by Circle INT TAX 1(3)(1) (hereinafter referred to as ‘the competent authority’) and consequential certificate dated 21.08.2025 issued under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) whereby the tax W.P.(C) 17641/2025 Page 1 of 7 Signature Not Verified Signed By:PRAMOD KUMAR VATS Signing Date:13.02.2026 17:55:02 withholding certificate (hereinafter referred to as ‘the certificate’) at the rate of 15% has been issued, as against petitioner’s request for issuance of ‘NIL’ rate certificate. 2. As per the pleadings of the petitioner, it is a company incorporated in the United Kingdom and is a tax resident thereof for Assessment Year (AY) 2026–27, having furnished a valid Tax Residency Certificate. The petitioner is engaged in providing subscription-based information and software products, which grant access to publicly available financial, economic, commercial and regulatory data, including market data, reports, news and other financial information. It also provides FXall products, being an electronic platform facilitating real-time online trading in foreign exchange ins