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

Judgment text excerpt

$~73 * 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 Page 1 of 7 Signature Not Verified Signed By:PRAMOD KUMAR VATS Signing Date:04.02.2026 14:46:50 certificate dated 17.04.2025 issued in furtherance thereof has also been challenged. 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 is engaged in providing electronic global distribution services (GDS) to the travel industry globally, through an automated Computer Reservation System (CRS). The services are provided to various airlines, and for each completed booking, the petitioner receives booking fees from the airlines. The petitioner receives some amount/commission in India, for which a lower tax withholding certificate was prayed.