* IN THE HIGH COURT OF DELHI AT NEW DELHI

% Judgment Reserved on: 22.11.2025

Judgment delivered on: 24.12.2025

Judgment uploaded on: As per Digital Signature~

+ W.P.(C) 15181/2004

M/S LG ELECTRONICS INDIA P.LTD & ANR ....Petitioners

versus

DIRECTOR OF INCOME TAX(INTERNATIONAL

TAXATION) & ANR .....Respondents

Advocates who appeared in this case

For the Petitioner : Mr. Deepak Chopra, Mr. Ankul Goyal and

Mr. Adwiteya Grover, Advocates.

For the Respondents : Mr. Indruj Singh Rai, SSC Mr. Sanjeev

Menon, Mr. Rahul Singh, JSCs and Mr.

Gaurav Kumar, Advocate.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO

HON'BLE MR. JUSTICE VINOD KUMAR

JUDGMENT

V. KAMESWAR RAO, J.

1. This writ petition has been filed by the petitioner No.1/LG Electronics India Pvt. Ltd. through its managing director/petitioner no.2 with the

following prayers:-

“a. to issue a writ of certiorari quashing the impugned order dated 27.04.2004 u/s 264 of the Act passed by

the respondent no.1 being perverse and bad in law;

b. to issue a writ of mandamus directing the respondents to grant permission to the petitioner no.1

u/s 195 of the Act to make remittances without deduction of tax;”

2. In effect, the petitioner is challenging the order dated 27.04.2004