PGS GEOPHYSICAL AS vs INCOME TAX DEPARTMENT, INTERNATIONAL TAX CIRCLE 2(2)(2) NEW DELHI & ANR.

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 02.12.2025 Judgment delivered on: 20.02.2026 Judgment uploaded on: As per Digital Signature~ W.P.(C) 9678/2025 PGS GEOPHYSICAL AS .....Petitioner versus INCOME TAX DEPARTMENT, INTERNATIONAL TAX CIRCLE 2(2)(2) NEW DELHI & ANR. .....Respondents Advocates who appeared in this case For the Petitioner : Mr. Salil Kapoor, Ms. Soumya Singh, Ms. Ananya Kapoor, Mr. Sumit Lalchandani and Ms. Sakshi Rustagi, Advocates For the Respondents : Mr. Gaurav Gupta, SSC, Mr.Shivendra Singh, Mr. YojitPareek, JSCs, Mr Surya Jindal, Advocate. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. The present petition has been filed seeking directions to quash a certificate and order dated 01.05.2025 (impugned order) passed by the respondent No.1/the Revenue under Section 197 of the Income Tax Act, 1961 (the Act) in the case of the petitioner for the Financial Year (FY) 2025- 26, relevant to Assessment Year (AY) 2026-27, whereby a withholding tax of 7% of gross receipts has been imposed on the petitioner. 2. At the outset, we may narrate a brief factual background of the present controvers