NORD ANGLIA EDUCATION LIMITED vs DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INT. TAX 2(2) (2), NEW DELHI

Judgment text excerpt

$ * IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 23.12.2025 Judgment delivered on: 14.01.2026 Judgment uploaded on: As per Digital Signature~ + W.P.(C) 13473/2025 NORD ANGLIA EDUCATION LIMITED .....Petitioner versus DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INT. TAX 2(2) (2), NEW DELHI .....Respondent Advocates who appeared in this case For the Petitioner : Dr. Shashwat Bajpai, Advocate For the Respondent : Mr. Shlok Chandra, SSC, Ms. Naincy Jain, JSC, Ms. Madhavi Shukla, JSC and Mr. Udit Dad, Advocate. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. This petition has been filed challenging an order dated 09.06.2025 and certificate dated 30.07.2025 issued by the respondent/Revenue, whereby the application of the petitioner/assessee under Section 197 read with Section 195(3) of the Income-tax Act, 1961 (the Act, hereinafter) seeking issuance of a „Nil Withholding Certificate‟ has been rejected. 2. The petitioner is a company incorporated under the laws of the United Kingdom, and is engaged in the business of providing international Signature Not Verified Signed By:PRADEEP WP(C) No.13473/2025 Page 1 of 16 SHARMA Signing Date:14.01.2026 14:57:56 education across the globe. The petitioner has a subsidiary in India, Nord Anglia Education India Pvt. Ltd. (Nord India, hereinafter), to which the petitioner extends routine management and administrative support services, including marketing and communication, human resources, finance, IT, and corporate development, which are subsequently recovered on a strict cost-to- cost basis without any markup. 3. According to Dr. Shashwat Bajpai, learned counsel for the petitioner, the services rendered by the petitioner are purely managerial in nature and do not pa