Case of Nord Angila Education Limited vs DCIT, HC Delhi Judgement Dated 14th January 2026. The petitioner applied for a Nil Withholding Certificate under Section 197, asserting that the consideration received was not chargeable to tax in India. ITAT in the petitioner’s own case, had already examined the very same services and held that they do not constitute fees for technical services under the India–UK DTAA. The Assessing Officer rejected the petitioner’s application for NIL TDS and directed deduction of tax at 15%, merely stating that determination of income at this stage was premature and that withholding was necessary to protect the interests of the Revenue. The court held this approach to be legally impermissible. Rule 28AA mandates that the Assessing Officer must determine the existing and estimated tax liability after taking into account tax payable on the estimated income.