Zscaler Inc vs Deputy Commissioner Of Income Tax, ...

ik-183663183 Delhi High Court 23 December 2025 • 38 min read

Judges (2)

V. Kameswar Rao Delivered Vinod Kumar Coram

Counsel (8)

Anugrah Dwivedi Counsel Respondent Arun Bhadauria Counsel Petitioner Kamal Sawhney Counsel Petitioner Priya Sarkar Counsel Respondent Puru Medhira Counsel Petitioner Sunil Agarwal Counsel Respondent Utkarsh Tiwari Counsel Respondent Viplav Acharya Counsel Respondent

Parties (2)

Deputy Commissioner of Income Tax, Circle 3(1)(1), New Delhi Respondent Zscaler Inc Petitioner

Case Significance

Zscaler Inc vs Deputy Commissioner Of Income Tax, ... is a Delhi High Court decision dated December 23, 2025 (citation: ik-183663183). Zscaler Inc, a US-incorporated company providing software-based IT solutions, challenged a Section 197 certificate that imposed withholding tax on prospective payments of Rs 13.19 billion, arguing its software resale income was not taxable in India. The court examined whether the Assessing Officer had properly considered the petitioner's application and the ITAT order in the petitioner's favour for the same assessment year. The impugned certificate and orders were set aside, and the AO was di The bench comprised Justices V. Kameswar Rao and Vinod Kumar. The judgment was delivered by Justice V. Kameswar Rao.

Summary

Zscaler Inc, a US-incorporated company providing software-based IT solutions, challenged a Section 197 certificate that imposed withholding tax on prospective payments of Rs 13.19 billion, arguing its software resale income was not taxable in India. The court examined whether the Assessing Officer had properly considered the petitioner's application and the ITAT order in the petitioner's favour for the same assessment year. The impugned certificate and orders were set aside, and the AO was directed to reconsider the application de novo within three weeks, granting the petitioner an opportunity of hearing.

What was the outcome of Zscaler Inc vs Deputy Commissioner Of Income Tax, ...?

Zscaler Inc, a US-incorporated company providing software-based IT solutions, challenged a Section 197 certificate that imposed withholding tax on prospective payments of Rs 13.19 billion, arguing its...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-183663183)