TRAVELPORT INTERNATIONAL OPERATIONS LIMITED vs DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE INT. TAX 3(1)(1), DELHI & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 28.01.2026 W.P.(C) 7633/2025, CM APPL. 34030/2025 TRAVELPORT INTERNATIONAL OPERATIONS LIMITED .....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Manuj Sabharwal, Mr. Drona Negi and Mr. Devvrat Tiwari, Advs. versus DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE INT. TAX 3(1)(1), DELHI & ORS. .....Respondents Through: Mr. Siddhartha Sinha, SSC and Ms. Easha Gurung, JSC CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (ORAL) 1. By way of the present writ petition, the petitioner has challenged the order dated 24.04.2025 passed by the Circle INT TAX 3(1)(1) DEL (hereinafter referred to as „the competent authority‟) whereby the petitioner’s application under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as „the Act of 1961‟) for the Assessment Year (AY) 2025-26 has been decided in the manner that the payer(s) making payment to the petitioner are required to deduct tax at the rate of 1.6%. The W.P.(C) 7633/2025 2. The petitioner is a company incorporated in the United Kingdom and for the purposes of Income Tax, a tax resident of the United Kingdom. The petitioner i