AECOM TECHNICAL SERVICES INC. vs. INCOME-TAX OFFICER WARD INT TAX 1(1)(1), DELHI & ORS.
What did the High Court hold?
The Delhi High Court held that the writ petition had indeed become infructuous. The Court reasoned that even if the relief sought by the petitioner were granted, it would be of no practical use. The Court cannot undertake a futile exercise that would yield no result for the petitioner, especially since the financial year 2023-24, for which the certificate was sought, had already passed. The Court also noted that for the subsequent period (financial year 2024-25), the petitioner had already been granted relief. The Court found that the 'Doctrine of Mootness,' cited by the petitioner, could not be applied in this case as the petition was rendered infructuous and no deduction or lower deduction could be ordered for transactions that occurred in the past financial year. Consequently, the petition was dismissed as infructuous.
What were the facts?
The petitioner, AECOM Technical Services Inc., filed a writ petition before the Delhi High Court challenging an order rejecting its prayer for a certificate of nil or lower rate deduction under Section 197 of the Income Tax Act, 1961. This order pertained to the financial year 2023-24 (relevant to Assessment Year 2024-25). The Income Tax Officer, Ward Int Tax 1(1)(1), Delhi, and others were the respondents. The petition remained pending for two years. The respondents argued that the petition had become infructuous because the financial year for which the certificate was sought had passed, and any relief granted would be for a period that had already concluded, rendering the exercise academic.
What were the issues?
1. Whether the writ petition seeking a certificate for nil or lower rate deduction under Section 197 of the Income Tax Act, 1961, for the financial year 2023-24 has become infructuous, rendering any relief futile. Assessee's Contention: The petitioner argued that the petition was filed within time and should not be considered infructuous due to the delay in its pendency, for which the petitioner was not at fault. They also referred to the 'Doctrine of Mootness' prevalent in the United States. Revenue's Contention: The respondents contended that the petition had been rendered infructuous because the financial year 2023-24 had passed. They argued that even if the petition were allowed, no relief could be granted as the certificate would relate to a period that had already concluded. Therefore, the Court should not engage in an academic exercise.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
$~38 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 4595/2024 AECOM TECHNICAL SERVICES INC. .....Petitioner Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari and Mr. Drona Negi, Advs. versus INCOME-TAX OFFICER WARD INT TAX 1(1)(1), DELHI & ORS. .....Respondents Through: Mr. Sunil Agarwal, SSC, Ms. Priya Sarkar, JSC and Mr. Anugrah Dwivedi, Advs. CORAM: HON’BLE MR. JUSTICE DINESH MEHTA HON’BLE MR. JUSTICE VINOD KUMAR O R D E R %
15.01.2026 1. Mr. Sunil Aggarwal, learned Senior Standing Counsel for the respondent-Income Tax Department, at the outset submitted that the present petition has been rendered infructuous inasmuch as the order rejecting the prayer for issuance of certificate at NIL rate or lower rate under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) was for the financial year 2023-24 (relevant to Assessment Year 2024-25). 2. He further submitted that even if the present petition is allowed as prayed, then also no relief can now be granted to the petitioner, as the certificate which is likely to be issued pursuant to the order of this Court would relate to financial year 2023-24, which period has since passed. He 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 19/01/2026 at 12:58:55
argued that such being the position, the Court should not enter into academic exercise. 3. Mr. Sabharwal on the other hand, submitted that the petition has not been rendered infructuous, as the petitioner had filed the petition well within time, which remained pending for two years, for which the petitioner cannot be faulted with. 4. Learned counsel for the petitioner invited Court’s attention to the doctrine called ‘Doctrine of Mootness’ prevalent in the United States. 5. According to us, the relief as prayed by the petitioner even if granted cannot be of any use. The Court cannot enter into exercise of futility which would bring no result to the petitioner. More particularly when, for the subsequent period (financial year 2024-25), the petitioner has already been granted relief from this Court. 6. The doctrine which has been cited by the petitioner, may be prevalent in the United States but the same cannot be applied in the facts of this case, when the petition itself has been rendered infructuous and no deduction or lower deduction can be ordered to be made on the transactions which took place between the year 2023-24. 7. The petition is, therefore, dismissed as infructuous. DINESH MEHTA, J VINOD KUMAR, J JANUARY 15, 2026/ss 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 19/01/2026 at 12:58:55
More judgments on Section 197
- Rajasthan Tourism Development Corporation… vs Asstt. Commissioner of Income Tax, Circle…ITA 3756/DEL/2026[2015-16]Status: Disposed5 Aug 2026AY 2015-16
- Addl.CIT, Special Range-6, New Delhi vs Makemytrip India Pvt. Ltd., GurgaonITA 6397/DEL/2017[2010-11]Status: Disposed31 Jul 2026AY 2010-11
- Aahvishkaar Training Services Pvt. Ltd… vs ITO, Corporate Ward-1(1), ChennaiITA 1444/CHNY/2026[2017-18]Status: Disposed16 Jul 2026AY 2017-18
- Shaila Suresh Bhujbal, Shikrapur vs Ward 13(4), PuneITA 578/PUN/2026[2017-18]Status: Disposed26 May 2026AY 2017-18
- Shaila Suresh Bhujbal, Shikrapur vs Ward 13(4) Pune, PuneITA 577/PUN/2026[2017-18]Status: Disposed26 May 2026AY 2017-18
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