British Airways Plc vs The Assistant Commissioner Of Income ...

ik-9669404 Delhi High Court 17 February 2026 • 5 min read

Judges (2)

Counsel (4)

Parties (2)

Case Significance

British Airways Plc vs The Assistant Commissioner Of Income ... is a Delhi High Court decision dated February 17, 2026 (citation: ik-9669404). British Airways challenged the issuance of a 0.1% tax withholding certificate under Section 197 of the Income Tax Act for its airline and cargo operations, when it had been receiving NIL rate certificates for the last sixteen years under the India-UK DTAA Article 8 exemption. The court set aside the certificate and directed the competent authority to issue a NIL rate certificate within seven days, noting the inconsistent approach showed non-application of mind by the bureaucracy. The bench comprised Justices Dinesh Mehta and Vinod Kumar. The judgment was delivered by Justice Dinesh Mehta. Counsel appearing: Anil Kumar (counsel for petitioner), Anurag Ojha (counsel for respondent), S.S. Tomar (counsel for petitioner), Vishal Kalra (counsel for petitioner).

Summary

British Airways challenged the issuance of a 0.1% tax withholding certificate under Section 197 of the Income Tax Act for its airline and cargo operations, when it had been receiving NIL rate certificates for the last sixteen years under the India-UK DTAA Article 8 exemption. The court set aside the certificate and directed the competent authority to issue a NIL rate certificate within seven days, noting the inconsistent approach showed non-application of mind by the bureaucracy.

What was the outcome of British Airways Plc vs The Assistant Commissioner Of Income ...?

British Airways challenged the issuance of a 0.1% tax withholding certificate under Section 197 of the Income Tax Act for its airline and cargo operations, when it had been receiving NIL rate certific...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-9669404)