TURNITIN INDIA PRIVATE LIMITED (FORMERLY KNOWN AS TURNIT INDIA EDUCATION PRIVATE LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 25(1) DELHI

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W.P.(C)/13943/2026HC DelhiDLHC01045269202629 September 2026Bench: HON'BLE DR. JUSTICE ADITI CHOUDHARY,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryRemanded

What did the High Court hold?

The Delhi High Court quashed the impugned order dated 30.06.2026 passed under Section 148A(3) and the impugned notice dated 30.06.2026 issued under Section 148 of the Income Tax Act, 1961. The Court took note of the fair stand taken by the respondent (revenue). The revenue's communication clearly indicated that the notice was issued due to a clerical error where information was uploaded against the wrong PAN (AAGCT1132P - M/s Turnitin India) instead of the intended PAN (AAATR3163K - Jagdishprasad Jhabarmal Tibrewala University). The revenue acknowledged this mistake and stated its intention to re-upload the information against the correct PAN. The principle derived is that notices and orders issued under Sections 148A and 148 of the Income Tax Act, 1961, based on demonstrable clerical errors admitted by the revenue, can be quashed. The respondent/Assessing Officer was explicitly permitted to initiate proceedings against the correct person to whom the information actually relates, in accordance with the law. No issue was left undecided.

What were the facts?

The petitioner, Turnitin India Private Limited, formerly Turnitin India Education Private Limited, filed a writ petition before the Delhi High Court. The challenge was to an order dated 30.06.2026 passed under Section 148A(3) and a notice dated 30.06.2026 issued under Section 148 of the Income Tax Act, 1961. The respondent was the Assistant Commissioner of Income Tax Circle 25(1) Delhi. The revenue, through its senior standing counsel, submitted an e-mail dated 23.09.2026 from the Assessing Officer. This e-mail explained that the notice was issued due to a clerical error and a mismatch of PAN details. Information was uploaded against the wrong PAN (AAGCT1132P - M/s Turnitin India) instead of the intended PAN (AAATR3163K - Jagdishprasad Jhabarmal Tibrewala University), despite the name mentioned being correct.

What were the issues?

1. Whether the impugned order dated 30.06.2026 passed under Section 148A(3) and the notice dated 30.06.2026 issued under Section 148 of the Income Tax Act, 1961, are liable to be quashed due to a clerical error in the PAN details leading to incorrect issuance against the petitioner? (Question of mixed law and fact, concerning Sections 148A and 148 of the Income Tax Act, 1961). Assessee's Contention: The petitioner implicitly sought the quashing of the impugned order and notice on the grounds of the clerical error. (No specific authorities or precedents were mentioned in the judgment for the petitioner's argument). Revenue's Contention: The revenue, through the Assessing Officer's e-mail, admitted to a clerical mistake in uploading information against the wrong PAN. The revenue acknowledged that the information was intended for Jagdishprasad Jhabarmal Tibrewala University and requested remedial action for the petitioner's case (PAN AAGCT1132P). The revenue stated its intention to re-upload the information against the correct PAN as a corrective measure in the interest of revenue.

Which sections of the Income-tax Act were involved?

Section 148A,Section 148

AI-generated summary — verify with the full judgment below

$~2 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010452692026 + W.P.(C) 13943/2026, CM APPL. 65135/2026 & CM APPL. 65136/2026 TURNITIN INDIA PRIVATE LIMITED (FORMERLY KNOWN AS TURNIT INDIA EDUCATION PRIVATE LIMITED

.....Petitioner Through: Dr.Shashwat Bajpai, Mr. Mayank Chaturvedi & Ms.Yagya Aggarwal, Advs. versus THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 25(1) DELHI .....Respondent Through: Mr. Puneet Rai, SSC with Mr.Ashvini Kr. & Mr. Rishabh Nangia, JSCs, Ms.Nancy Jain, Mr. Nikhil Jain & Mr.Aryan Mittal, Advs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE DR. JUSTICE ADITI CHOUDHARY O R D E R %

29.09.2026 1. Mr. Puneet Rai, learned senior standing counsel for the respondent has handed over a printout of the e-mail dated 23.09.2026 sent by the Assessing Officer informing that the notice had been issued to the petitioner on account of some clerical error and due to mismatch of the PAN details. The said communication dated 23.09.2026 is taken on record. The relevant paragraph of the said communication is reproduced hereunder: “5. Since the information was uploaded for multiple 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 01/10/2026 at 12:09:03

contributors, the bulk uploading facility was used. And due to inadvertent Clerical mistake, information was uploaded against the wrong PAN i.e., AAGCT1132P instead of intended PAN AAATR3163K (Jagdishprasad Jhabarmal Tibrewala University). Even though the name mentioned in the information uploaded was correct as Jagdishprasad Jhabarmal Tibrewala University. Given the above factual matrix, your goodself is requested to do the remedial action at your end in the case of (PAN AAGCT1132P - M/s Turnitin India). While as a corrective measure in the interest of revenue this office will reupload the information against the correct PAN of Jagdishprasad Jhabarmal Tibrewala University.” 2. In view of the fair stand taken by the respondent, the impugned order dated 30.06.2026 passed under Section 148A(3) so also the impugned notice of even date issued under Section 148 of the Income Tax Act, 1961 are hereby quashed. 3. Needless to observe that the respondent/Assessing Officer shall be free to initiate proceedings against the person to whom the information actually relates to, in accordance with law. 4. The writ petition stands disposed of. All pending applications are also disposed of. DINESH MEHTA, J ADITI CHOUDHARY, J SEPTEMBER 29, 2026 kk 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 01/10/2026 at 12:09:03

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