Pgs Geophysical As vs Income Tax Department, International ...

ik-164472771 Delhi High Court 20 February 2026 • 43 min read

Judges (2)

V. Kameswar Rao Delivered Vinod Kumar Coram

Counsel (9)

Ananya Kapoor Counsel Petitioner Gaurav Gupta Counsel Respondent Sakshi Rustagi Counsel Petitioner Salil Kapoor Counsel Petitioner Shivendra Singh Counsel Respondent Soumya Singh Counsel Petitioner Sumit Lalchandani Counsel Petitioner Surya Jindal Counsel Respondent Yojit Pareek Counsel Respondent

Parties (2)

Income Tax Department, International Tax Circle 2(2)(2) New Delhi Respondent PGS Geophysical AS Petitioner

Case Significance

Pgs Geophysical As vs Income Tax Department, International ... is a Delhi High Court decision dated February 20, 2026 (citation: ik-164472771). Norwegian company PGS Geophysical AS challenged a Section 197 Income Tax Act withholding tax certificate imposing 7% tax on gross receipts for seismic survey services provided to the oil and gas industry in India for FY 2025-26. The court set aside the impugned order, finding that the AO had failed to consider the binding precedent of the court's own earlier judgment in PGS Exploration (Norway) AS and provided no reasoning on how receipts constituted Royalty under Section 9(1)(vi) or fell wit The bench comprised Justices V. Kameswar Rao and Vinod Kumar. The judgment was delivered by Justice V. Kameswar Rao.

Summary

Norwegian company PGS Geophysical AS challenged a Section 197 Income Tax Act withholding tax certificate imposing 7% tax on gross receipts for seismic survey services provided to the oil and gas industry in India for FY 2025-26. The court set aside the impugned order, finding that the AO had failed to consider the binding precedent of the court's own earlier judgment in PGS Exploration (Norway) AS and provided no reasoning on how receipts constituted Royalty under Section 9(1)(vi) or fell within Section 44DA. The matter was remanded for fresh consideration within three weeks.

What was the outcome of Pgs Geophysical As vs Income Tax Department, International ...?

Norwegian company PGS Geophysical AS challenged a Section 197 Income Tax Act withholding tax certificate imposing 7% tax on gross receipts for seismic survey services provided to the oil and gas indus...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-164472771)