2026 (2) TMI 1093

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... impugned order dated 22.07.2025 and corresponding certificate dated 11.07.2025 issued to the petitioner under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act of 1961') subject to withholding tax at rate of 15%. 2. As pleaded, the petitioner is a non-resident company incorporated under the laws of United States of America. The petitioner provides a wide range of products including foreign exchange related Matching solutions, real-time financial data, etc. The petitioner also provides a number of support services to its group companies. 3. A brief summary of the above products and offerings of the company are given below: a) Matching solutions: The company provides global market electronic solution....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....law to the case of Financial And Risk Organisation Limited v. The Income Tax Officer Int. Tax 1(3)(1) New Delhi, W.P.(C) 17641/2025 which was decided vide order dated 10.02.2026, wherein this Court directed the competent authority to issue a certificate at NIL rate, as the issue was covered in favour of the assessee by way of at least two judgments of the Income Tax Appellate Tribunal (hereinafter referred to as 'the Tribunal'). 7. He further submitted that even the services covered by the second agreement, being Support services are not taxable in India under any of the relevant provision, but ignoring such legal position, the competent authority has passed the impugned order and issued a certificate at 15% instead of the petitioner's p....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... rate within fifteen days from today so far as Matching solution is concerned. We also direct him to continue to issue certificate(s) at 'NIL' rate for each subsequent year within thirty days of the application being filed by the petitioner, for Matching solution. 13. For the purpose of clarity, the directions are enumerated hereunder ; i. The competent authority is directed to issue a certificate at 'NIL' rate so far as the agreement in relation to Matching solution is concerned, for which the petitioner has entered into an agreement(s) for an amount of Rs. 65,97,09,956/-. ii. So far as the second agreement qua Support services (for Rs. 67,40,636/-) is concerned, the certificate at 15% be issued for this year. ....