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

Judgment text excerpt

* 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. Signature Not Verified Signed By:PRADEEP WP(C) No.9678/2025 Page 1 of 38 SHARMA Signing Date:20.02.2026 18:36:05 2. At the outset, we may narrate a brief factual background of the present controversy, as borne out from the petition. The petitioner is a non- resident company and is incorporated in Norway. It is engaged in the business of providing geophysical services to oil and gas industry. It conducts seismic surveys and provides offshore seismic data acquisition and other associated services such as processing and interpretation of such data. On 20.11.2024, the petitioner received a Letter of Award (LOA) from the Oil and Natural Gas Commission (ONGC) bearing no.DLI/2024/B