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* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 23.12.2025 Judgment delivered on: 14.01.2026 Judgment uploaded on: As per Digital Signature~

+ W.P.(C) 16158/2025 & CM APPL. 66147/2025 ERNST AND YOUNG LLP .....Petitioner versus ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL CIRCLE-1-2-2, NEW DELHI .....Respondent Advocates who appeared in this case For the Petitioner : Mr. Kamal Sawhney, Mr. Arun Bhadauria and Mr. Nishank Vashishta, Advocates For the Respondents : Mr. Indruj Singh Rai, SSC, Mr. Sanjeev Menon, JSC 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 petition has been filed with the following prayers:-

“(i) Issue a writ of certiorari and/or any other writ, order or direction in the nature of certiorari setting aside the Impugned Certificate dated 17.09.2025 r/w Impugned Order dated 17.09.2025;

(ii) issue a writ of mandamus and/or any other writ, order or direction in the nature of mandamus directing the respondent to issue a “nil withholding” certificate for prospective payments amounting to 17,50,00,00,000/- to be paid by the petitioner to its payee Ernst & Y