APTIV GLOBAL OPERATIONS LIMITED vs. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)- 1, DELHI & ANR.

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W.P.(C)/1938/2025HC DelhiDLHC01007198202523 February 2026Author: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryWithdrawn

What did the High Court hold?

The Delhi High Court held that even if the impugned order were set aside and the matter decided in favor of the petitioner, no practical relief would accrue to the assessee because the relevant financial year (2024-25) had already concluded. Therefore, the Court found no fruitful purpose in undertaking the exercise of deciding the petition on merits and brought the proceedings to a close. The Court disposed of the writ petition as infructuous. It clarified that the petitioner is free to file applications under Section 197 for subsequent years if advised, and any such application should be decided by the Competent Authority in accordance with law, without being influenced by the previous order. If any subsequent order is prejudicial to the petitioner, they are free to pursue legal remedies.

What were the facts?

The petitioner, Aptiv Global Operations Limited, challenged an order and certificate dated 23.10.2024 passed by the Deputy Commissioner of Income Tax under Section 197 of the Income Tax Act, 1961. The assessment year in question was Financial Year 2024-25. The respondents, represented by the Commissioner of Income Tax (International Taxation)-1, Delhi, argued that since the entire financial year had passed, the writ petition had become infructuous. The petitioner contended that the impugned order was illegal and lacked proper reasoning. The petitioner also indicated that applications for subsequent years might not have been filed due to apprehension of similar adverse decisions.

What were the issues?

1. Whether the writ petition challenging the order passed under Section 197 of the Income Tax Act, 1961, for Financial Year 2024-25 is rendered infructuous given that the financial year has concluded? (Question of mixed law and fact). Assessee's Contention: The impugned order dated 23.10.2024 is illegal and lacks proper reasoning, thus requiring the petition to be heard and decided on merits. The petitioner also apprehended similar adverse decisions for subsequent years, which might have deterred them from filing applications for those years. Revenue's Contention: The writ petition has become infructuous as the Financial Year 2024-25 has entirely passed.

Which sections of the Income-tax Act were involved?

Section 197

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 1938/2025 & CM APPL. 9067/2025 APTIV GLOBAL OPERATIONS LIMITED .....Petitioner Through: Mr. Shankey Agrawal, Mr, Harsh Shukla & Ms. Pratha Khanna Advs. versus COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)- 1, DELHI & ANR. .....Respondents Through: Mr. Indruj Singh Rai, Sr. Standing Counsel. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

23.02.

2026

1.

By way of the present writ petition, the petitioner has challenged the order so also the certificate dated 23.10.2024 passed by the Deputy Commissioner of Income Tax, Office of Circle International Tax-1(1)(1), New Delhi, under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as „the Act of 1961‟).

2.

Learned Senior Standing Counsel for the respondents submitted that the year involved in the present case is Financial Year 2024-25 and since the entire period has passed, the petition has been rendered infructuous.

3.

Learned counsel for the petitioner, on the other hand submitted that the impugned order dated 23.10.2024 is illegal and since no reasons worth the name has been mentioned, the petition is required to be heard and decided.

4.

On Court’s query, learned counsel for the petitioner informed that for This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/02/2026 at 15:35:30

subsequent years, no application under Section 197 of the Act of 1961 has been filed by the petitioner. He, however, submitted that the application(s) might not have been filed, as the petitioner was apprehending that the applications for subsequent years too will be decided in a similar fashion.

5.

Having heard learned counsel for the parties and considering that even if we set aside the impugned order, and decide the matter in favour of the petitioner-assessee, no relief as a matter of fact, would percolate into the hands of the assessee. We feel that no fruitful purpose would be served by undertaking the exercise. We, thus, bring the present proceedings to a close.

6.

While disposing of the writ petition as infructuous, we hereby make it clear that the petitioner may file application under Section 197 of the Act of 1961 for subsequent year(s) if so advised.

7.

In case, the application is filed, the Competent Authority shall decide the same in accordance with law without being influenced by the order dated 23.10.2024, which he had passed in the Financial Year 2024-25. 8. In case, the order of the Competent Authority is, in any manner, prejudicial to the petitioner’s right, it shall be free to take up remedies in accordance with law. The disposal of the present writ petition obviously shall not come in petitioner’s way.

9.

The writ petition along with the pending application stands disposed of.

DINESH MEHTA, J

VINOD KUMAR, J FEBRUARY 23, 2026/kk This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/02/2026 at 15:35:30

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