Conjoint Healthcare Private Limited V. Income Tax Officer and another

CWP/6897/2025

AI Insights

The case involves Conjoint Healthcare Private Limited, the petitioner, contesting the adjustment of a tax refund against an outstanding demand for a different assessment year by the Income Tax Officer and another respondent. The petitioner argued that the refund for the assessment year 2024-25 was improperly adjusted against dues for the assessment year 2022-23, especially since part of the demand for 2022-23 was stayed by the Assessing Officer. The court considered the procedural steps taken by the respondents, including raising a ticket with the Central Processing Centre in Bengaluru, and found that despite these actions, the refund had not been released. The court's decision focused on ensuring the timely release of the refund while allowing the petitioner to pursue any claims for interest separately.

• Counselvise Citation: [] 140 COUNSELVISE.COM (IT) 842484 (HC-CHANDIGARH)
• Appeal Type: Others
• Pronouncement Date: 25-02-2026
• Assessment Year: misc
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: RANVIJAYSINGH; NIKITA GARG; VIDUL KAPOOR; URVASHI DHUGGA; VAIBHAV GUPTA; KAVITA
• Assessee Lawyers: NIKHIL GOYAL
• Keywords: Assessment Year; Income Tax; Outstanding Demand; Refund adjustment
• Section: 246A; 245

Judgement Text

" CWP-6897-2025 1 IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH 295 CWP-6897-2025 (O&M) Date of Decision: 25.02.2026 Conjoint Healthcare Private Limited .....Petitioner Versus Income Tax Officer and another .....Respondents CORAM: HON'BLE MRS. JUSTICE LISA GILL HON'BLE MR. JUSTICE RAMESH CHANDER DIMRI Present: Mr. Nikhil Goyal, Advocate for the petitioner (through V.C). Mr. Ranvijay Singh, Senior Standing Counsel with Ms. Nikita Garg, Advocate and Mr. Vidul Kapoor, Advocate for respondent No.1. Ms. Urvashi Dhugga, Senior Standing Counsel with Mr. Vaibhav Gupta, Jr. Standing Counsel for CPC with Ms. Kavita, Advocate for respondent No.2. **** LISA GILL , J.(Oral) 1. Prayer in this writ petition is for setting aside intimation dated 03.03.2025 (Annexure P-9) re-adjustment of refund of Rs.42,62,860/- for the Assessment Year 2024-25 against the outstanding demand for Assessment Year 2022-23 by respondent No.2. There is further prayer for directing the respondents to release the abovesaid amount which has statedly been illegally and arbitrarily adjusted against the outstanding demand of Assessment Year 2022-23. 2. It is pointed out that while issuing notice of motion on 11.03.2025, contentions on behalf of petitioner were noted as under: “The petitioner (Conjoint Healthcare Private Limited) impugns the intimation dated March 03, 2025, whereby, subject to Section 245 (2) of the Income Tax Act, 1961 (1961 Act), the Central Processing Centre, Bengaluru, has informed that refund due to it, for the assessment year 2024-25 (Rs.42,62,860/-), had since been adjusted against the outstanding dues as regards the assessment year 2022-23. Learned counsel for the petitioner submits that the adjustment, indicated above, was carried out after intimation to the petitioner under Section 245 of the 1961 Act, on February Printed from counselvise.com RAJEEV PUROHIT 2026.02.27 15:44 I attest to the accuracy and integrity of this document CWP-6897-2025 2 10, 2025, which was duly responded to on March 03, 2025 (P- 8). He asserts that, in fact, the petitioner had filed an appeal against the demand (Rs.1,05,80,070/-) for the year 2022-23, raised vide notice dated Mach 27, 2024, under Section 246A of the 1961 Act, and the same is pending. And, on payment of Rs.5,00,000/- on May 08, 2024, rest of the demand (Rs.1,00,80,070/-) had since been stayed by the Assessing Officer on September 20, 2024 (P-4). Thus, under no conceivable circumstances, the authority could still adjust the refund the petitioner was entitled to against the outstanding dues for the assessment year 2022-23.” 3. Learned counsel for respondent-department had earlier informed the Court that authorities have raised a ticket with the Central Processing Centre, Bengaluru and the matter is being processed and is at an advanced stage. Matter had been adjourned to enable learned counsel for respondent to apprise the Court of final outcome of the said proceedings. 4. Learned counsel for petitioner submits that amount in question has still not been released despite the raising of ticket. 5. Keeping in view facts and circumstances as above and the specific stand of the department that the ticket has been so raised, respondent No.2 is directed to take necessary steps in this regard and the refund be made expeditiously and definitely within a period of two months. In respect to claim, if any qua interest, liberty is granted to the petitioner to raise it in accordance with law, if so advised. 6. Writ petition is accordingly disposed of. 7. Pending application(s), if any, is/are disposed of. (LISA GILL) JUDGE (RAMESH CHANDER DIMRI) JUDGE 25.02.2026 Rajeev (rvs) Whether speaking/reasoned Yes/No Whether reportable Yes/No Printed from counselvise.com RAJEEV PUROHIT 2026.02.27 15:44 I attest to the accuracy and integrity of this document "