Withholding Without Basis

This note by J the app, examines the judgment of the Delhi High Court in W.P.(C) 17641/2025, decided on 10 February 2026, concerning issuance of a withholding tax certificate under Section 197 of the Income Tax Act, 1961. The case assumes significance for multinational digital service providers operating in India through distribution models and for the jurisprudence governing Section 197 applications