ITA 212/2025 etc. $~24 to 26 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010979992023 + ITA 212/2025 & CM APPL. 40127/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through: Mr. Ruchir Bhatia SSC, Pratyaksh Gupta, JSC and Mr. Anant Mann, JSC for IT Dept/Appellant versus TRAVELPORT INTERNATIONAL OPERATIONS LTD. .....Respondent Through: Ms. Ishita Farsaiya, Mr. Sparsh Bhargava, Ms. Vanshika Taneja, Mr. Aryan Singh, Mr. Jaidev Prasada, Ms. Siddhi Sharma Advocates (25) # CNR No. DLHC010979972023 + ITA 219/2025 & CM APPL. 40207/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through: Mr. Ruchir Bhatia SSC, Pratyaksh Gupta, JSC and Mr. Anant Mann, JSC for IT Dept/Appellant versus TRAVELPORT INTERNATIONAL OPERATIONS LTD. .....Respondent Through: Ms. Ishita Farsaiya, Mr. Sparsh Bhargava, Ms. Vanshika Taneja, Mr. Aryan Singh, Mr. Jaidev Prasada, Ms. 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 28/09/2026 at 11:19:18 ITA 212/2025 etc. Siddhi Sharma Advocates (26) # CNR No. DLHC010447612025 + ITA 233/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through: Mr. Ruchir Bhatia SSC, Pratyaksh Gupta, JSC and Mr. Anant Mann, JSC for IT Dept/Appellant versus TRAVELPORT INTERNATIONAL OPERATIONS LTD. .....Respondent Through: Ms. Ishita Farsaiya, Mr. Sparsh Bhargava, Ms. Vanshika Taneja, Mr. Aryan Singh, Mr. Jaidev Prasada, Ms. Siddhi Sharma Advocates CORAM: HON'BLE MR. JUSTICE SUBRAMONIUM PRASAD HON'BLE MS. JUSTICE RENU BHATNAGAR O R D E R % 23.09.2026 1. Learned Counsel for the Appellant states that the questions raised before this Court are covered by the Judgment passed by the Apex Court in Commissioner of Income Tax (International Taxation) v. Travelport L.P. USA, (2023) 153 Taxman.com 176 (SC) and the same has been followed by this Court in the Order dated 24.07.2025 titled as Commissioner of Income Tax-International Taxation-3 v. Travelport International Operations Ltd., ITA 239/2025, wherein the Coordinate Bench of this Court has 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 28/09/2026 at 11:19:18 ITA 212/2025 etc. observed as under:- “2. Mr. Ruchir Bhatia, learned counsel for the appellant/revenue fairly states that in view of the judgment in “Commissioner of Income-tax (International Taxation) v. Travelport L.P. USA, [2023] 153 taxmann.com 176 (SC), the issue stands covered against the revenue herein. He also states that the appeals concerning Assessment Years 2007-08 to 2014-15 have been decided by this Court in ITA 718/2013 to ITA 731/2023 on 08.12.2023 against the Revenue. In this regard, he has placed before us the said order. The relevant part of the said order, paragraph 9 thereof, reads as under: “9. The moot point on merits which obtained in the appeals preferred by the appellant/revenue before the Tribunal was whether the view taken by CIT(A) that 15 percent of the profits earned from Indian operations could be attributed to the respondent/assessee was sustainable. The coordinate bench of AY 2006-07 while dealing with ITA 301/2022 has sustained the said conclusion and gone on to hold that no substantial question of law arose for its consideration. It is this decision which was affirmed by the Supreme Court with the dismissal of the SLP as noted hereinabove.” 3. In view of the position of law as laid down by the Supreme Court in Commissioner of Income-tax (International Taxation)(supra) as followed in respect of the Assessment Years 2007-08 to 2014-15, the issue having been decided against the revenue, no substantial question of law arises for consideration in this appeal. The appeal alongwith pending applications being without merit, is dismissed.” 2. In view of the said statement, the appeals are disposed of along with 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 28/09/2026 at 11:19:18 ITA 212/2025 etc. pending application(s), if any. SUBRAMONIUM PRASAD, J RENU BHATNAGAR, J SEPTEMBER 23, 2026 hsk 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 28/09/2026 at 11:19:18