Refinitiv Us Llc vs The Income Tax Officer Circle Int. Tax ...

ik-116674303 Delhi High Court 17 February 2026 • 6 min read

Judges (2)

Dinesh Mehta Delivered Vinod Kumar Coram

Counsel (7)

Ajay Vohra Counsel Petitioner Gibran Naushad Counsel Respondent Mayank Chaturvedi Counsel Petitioner Monica Benjamin Counsel Respondent Rohit Chakraborty Counsel Respondent Shashwat Bajpai Counsel Petitioner Sunil Agarwal Counsel Respondent

Parties (2)

Refinitiv US LLC Petitioner The Income Tax Officer Circle Int. Tax 1(3)(1) New Delhi Respondent

Case Significance

Refinitiv Us Llc vs The Income Tax Officer Circle Int. Tax ... is a Delhi High Court decision dated February 17, 2026 (citation: ik-116674303). Refinitiv US LLC, a non-resident US company providing financial data, forex matching solutions, and support services, challenged a Section 197 certificate issued with 15% withholding tax on its income from India. The key issue was whether the company's income from Matching solutions and Conversational Dealing constituted royalty/fees for technical services or business profits, and whether the company had a Permanent Establishment in India. The petition was partly allowed — the Court directed The bench comprised Justices Dinesh Mehta and Vinod Kumar. The judgment was delivered by Justice Dinesh Mehta.

Summary

Refinitiv US LLC, a non-resident US company providing financial data, forex matching solutions, and support services, challenged a Section 197 certificate issued with 15% withholding tax on its income from India. The key issue was whether the company's income from Matching solutions and Conversational Dealing constituted royalty/fees for technical services or business profits, and whether the company had a Permanent Establishment in India. The petition was partly allowed — the Court directed issuance of a nil withholding certificate for Matching and Conversational Dealing products while leaving the Support services issue open for future determination.

What was the outcome of Refinitiv Us Llc vs The Income Tax Officer Circle Int. Tax ...?

Refinitiv US LLC, a non-resident US company providing financial data, forex matching solutions, and support services, challenged a Section 197 certificate issued with 15% withholding tax on its income...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-116674303)