MUFG BANK LTD V. ASSISTANT COMMISSIONER OF INCOME TAX & ORS.

W.P.(C)/7842/2023

AI Insights

MUFG Bank Ltd filed two writ petitions against the Assistant Commissioner of Income Tax concerning rectification orders for the assessment years 1996-97 and 2001-02. The core issue revolved around the bank's grievances regarding the non-acknowledgment and incorrect calculation of refunds due for the mentioned years. The respondent's counsel presented rectification orders dated 07.01.2026, which accepted the petitioner's contentions and calculated the appropriate refunds, including interest as per Sections 244A and 244A(1A) of the Income Tax Act, 1961. With these developments, the court found the petitions to be infructuous and dismissed them, directing the prompt processing of the refunds.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 830422 (HC-DELHI)
• Appeal Type: Others
• Pronouncement Date: 14-01-2026
• Assessment Year: misc
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: DELPHINA SINGHLAI
• Assessee Lawyers: HITEN THAKKAR; NIKHIL RANJA
• Keywords: Assessment Year; Income Tax; Rectification orders; Refund
• Section: 244A; 244A(1A)

Judgement Text

"$~20 & 21 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 7835/2023 MUFG BANK LTD .....Petitioner Through: Mr. Hiten Thakkar, Mr. Nikhil Ranja, Advs. versus ASSISTANT COMMISSIONER OF INCOME TAX & ORS. .....Respondent Through: Ms. Delphina Singhlai, Adv. 21 + W.P.(C) 7842/2023 MUFG BANK LTD .....Petitioner Through: Mr. Hiten Thakkar, Mr. Nikhil Ranja, Advs. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1) AND ORS. .....Respondents Through: Ms Delphina Singhlai, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 14.01.2026 1. Ms Delphina Singhlai, learned proxy counsel appearing for Mr. Debesh Panda, learned Senior Standing Counsel, at the outset submits that the respondent-Assessing Officer (Deputy Commissioner of Income Tax 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 13:07:54 Printed from counselvise.com Circle 2(2)(1) International Taxes), New Delhi has passed two rectification orders dated 07.01.2026 for Assessment Year (hereinafter referred to as ‘AY’) 1996-97 and AY 2001-02, and accepted the petitioner’s contention and has calculated the refund for the subject years. Copies of the orders dated 07.01.2026 have been produced for perusal of the court, which are taken on record. 2. She further submits that in view of the aforesaid orders passed by the Assessing Officer and calculation of refund payable to the petitioner, which includes applicable interest under Section 244A and 244A(1A) of the Income Tax Act, 1961, petitioner’s grievance stands resolved. 3. In view of the aforesaid statement made by learned counsel for respondent, both these petitions are dismissed as having become infructuous. 4. The respondents are directed to refund/pay the applicable refund amount to the petitioner, in its bank account (if not already paid) as early as possible, preferably within a period of 30 days. 5. In case any of petitioner’s grievance still subsists, it shall be free to move rectification application before the Assessing Officer within a period of 30 days from today or move an application for revival of the present petition, which shall be considered in accordance with law. DINESH MEHTA, J VINOD KUMAR, J JANUARY 14, 2026/dd 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 13:07:54 Printed from counselvise.com "