AECOM INTERCONTINENTAL HOLDINGS UK LTD. vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI & ORS.

Judgment text excerpt

$~239 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of decision: 4th February, 2026. + W.P.(C) 14299/2025, CM APPL. 58549/2025 & CM APPL. 7329/2026 AECOM INTERCONTINENTAL HOLDINGS UK LTD. .....Petitioner Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari and Mr. Drona Negi, Advocates. versus ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI & ORS. .....Respondents Through: Mr. Anurag Ojha, SSC with Ms. Hemlata Rawat and Mr. V.K. Saksana, JSC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (Oral) 1. By way of present writ petition, the petitioner has challenged the order dated 19.08.2025 passed by and consequential certificate of even date issued by respondent No.1- Assistant Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi (hereinafter referred to as the „Competent Authority) under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as „the Act of 1961‟). 2. As per the petitioner, it is engaged in the business of providing corporate and management services, in terms of the agreement with its Associate Enterprise (AE) i.e. AECOM India Private Limited. The petitioner Signature Not Verified Digitally Signed W.P.(C) 14299/2025 Page 1 of 6 By:NAVEEN KUMAR Signing Date:12.02.2026 18:07:52 provides management and governance support functions in the area of legal, tax, treasury, finance, information technology, human resources, enterprise risk management, etc. 3. Mr. Manuj Sabharwal, learned counsel for the petitioner submitted that considering the very same entity with which the petitioner has dealt with in the preceding year and for the very services, this Court has already allowed the petitioner’s writ petition being W.P.(C) 10843/2024 vide its order dated 20.05.2025 and directed the