SUNLAND ALLOYS vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 61(1), DELHI AND ANR
What did the High Court hold?
The Delhi High Court held that substantial compliance had been made by the Income Tax Department, as the petitioner had received the refund and interest under Section 244A. However, the Court directed the Assessing Officer (AO) or the concerned authority to make the payment of applicable statutory interest under Section 244A(1A) of the Act of 1961 within a period of six weeks from the date of the order. The Court also stipulated that if the due interest was not paid by July 15, 2026, the petitioner would be at liberty to apply for the revival of the writ petition. The ratio decidendi is that while partial compliance might be acknowledged, the obligation to pay all statutory interest remains, and failure to do so can lead to the revival of proceedings. No issue was expressly left undecided.
What were the facts?
The petitioner, Sunland Alloys, filed a writ petition before the Delhi High Court challenging an order or action by the Assistant Commissioner of Income Tax Circle 61(1), Delhi. During the pendency of this writ petition, the petitioner received a refund and interest under Section 244A of the Income Tax Act, 1961. However, the petitioner contended that the interest under Section 244A(1A) of the Act of 1961 had not been calculated and paid by the Income Tax Department. The amount in dispute regarding the uncalculated interest is not specified. The procedural history involves the filing of the writ petition and subsequent developments during its pendency.
What were the issues?
1. Whether the Income Tax Department has made substantial compliance with its statutory obligations regarding the payment of interest under Section 244A of the Income Tax Act, 1961, by paying the refund and some interest, but failing to calculate and pay interest under Section 244A(1A). The Assessee (Petitioner) argued that while a refund and interest under Section 244A were received, the specific interest due under Section 244A(1A) had not been paid, indicating a shortfall in compliance. The Revenue (Respondents) did not explicitly record arguments in the judgment. However, their implicit stance was that substantial compliance had been made, as evidenced by the refund and interest already paid.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
O R D E R %
2026
Mr. Aditya Gupta, learned counsel for the petitioner informs that during the pendency of the present writ petition, the petitioner has received the refund so also interest under Section 244A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’). He however, submitted that the interest under Section 244A(1A) of the Act of 1961 has not been calculated and paid by the Income Tax Department.
Since substantial compliance has been made, we dispose of the present petition with the direction to the Assessing Officer (AO)/concerned authority to make payment of applicable statutory interest under Section 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 22/05/2026 at 12:45:07
244A(1A) of the Act of 1961 within a period of six weeks’ from today.
In case, the due interest is not paid by 15.07.2026, the petitioner shall be free to apply for revival of the petition.
The pending application is also disposed of. DINESH MEHTA, J VINOD KUMAR, J MAY 20, 2026/cd 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 22/05/2026 at 12:45:07
More judgments on Section 244A
- Shailesh Khodabhai Ramani, Rajkot vs ITO, Ward-2(1)(3), RajkotITA 366/RJT/2024[2012-13]Status: Disposed15 Oct 2026AY 2012-13
- Shailesh Khodabhai Ramani, Rajkot vs ITO, Ward-2(1)(5), RajkotITA 257/RJT/2024[2011-12]Status: Disposed15 Oct 2026AY 2011-12
- Credit Agricole Corporate and Investment… vs The Assistant Commissioner of Income-Tax…ITA 3453/MUM/2026[2022-23]Status: Disposed8 Oct 2026AY 2022-23
- Credit Agricole Corporate and Investment… vs The Assistant Commissioner of Income Tax…ITA 6805/MUM/2024[2021-22]Status: Disposed8 Oct 2026AY 2021-22
- Pratibha Sanjai Srivastava, Ahmedabad vs Income Tax Officer, Ward 7(2)(1), AhmedabadITA 2565/AHD/2026[2021-2022]Status: Disposed29 Sept 2026AY 2021-2022
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