CONNER INSTITUTE OF HEALTH CARE AND RESEARCH CENTER PVT. LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

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W.P.(C)/11027/2025HC DelhiDLHC01050646202529 July 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryRemanded

What did the High Court hold?

The Delhi High Court disposed of the writ petition along with pending applications. The Court took on record the submission made by the learned counsel for the respondent that the respondent would consider the writ petition itself as a representation of the petitioner and decide the same by passing a reasoned order within a period of six weeks from the date of the order, which was July 29, 2025. The decision would be communicated to the petitioner. The Court did not make any specific findings on the validity, legality, or time-barring of the notices issued under Section 201(1)/201(1A) as the matter was resolved by the undertaking given by the revenue to pass a reasoned order. No issue was expressly left undecided, as the petition was disposed of based on the respondent's commitment.

What were the facts?

The petitioner, Conner Institute of Health Care and Research Center Pvt. Ltd., filed a writ petition before the Delhi High Court challenging notices issued under Section 201(1)/201(1A) of the Income Tax Act, 1961, for the Financial Year 2019-20. The petitioner contended that despite filing replies to multiple notices dated 23.06.2021, 13.01.2023, 24.01.2023, 19.06.2025, and 17.07.2025, no response or decision was forthcoming from the respondent, the Deputy Commissioner of Income Tax. The petitioner sought to set aside these notices as invalid, illegal, or time-barred and requested a stay on the proceedings. The assessment year in question is 2019-20.

What were the issues?

1. Whether the notices dated 23.06.2021, 13.01.2023, 24.01.2023, 19.06.2025, and 17.07.2025 issued under Section 201(1)/201(1A) of the Income Tax Act for Financial Year 2019-20 are invalid, illegal, or time-barred? (Question of law and fact, concerning Section 201(1)/201(1A) of the Income Tax Act). Assessee's Contention: The petitioner argued that the notices were invalid, illegal, or time-barred. They also contended that despite submitting replies to the notices, no order or decision had been passed by the respondent, leading to a lack of response or resolution. Revenue's Contention: The respondent, represented by Mr. Ruchir Bhatia, stated that if the petitioner's sole grievance was the lack of a decision, they would consider the writ petition as a representation and pass a reasoned order within six weeks.

Which sections of the Income-tax Act were involved?

Section 201(1),Section 201(1A)

AI-generated summary — verify with the full judgment below

$~69 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 11027/2025 CM APPL. 45399/2025(Stay) CONNER INSTITUTE OF HEALTH CARE AND RESEARCH CENTER PVT. LTD .....Petitioner Through: Mr. Mukesh Gupta, Mr. S. B. Gandhi, Advs.

versus

DEPUTY COMMISSIONER OF INCOME TAX .....Respondent Through: Mr. Ruchir Bhatia, SSC, Mr. Anant Mann, Mr. P. Gupta, JSCs.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

29.07.2025 1. This petition has been filed with the following prayers: “1. To set aside the notices dated 23.06.2021, 13.01.2023, 24.01.2023,19.01.2025 and 17.07.2025 issued under section 201(1)/201(1A) of theIncome Tax Act for Financial Year 2019-20 for seeking details /verification of TDS returns as per the above referred notices either beinginvalid, illegal or time barred. 2. To stay the proceedings initiated u/s 201(1)/ 201(1A) of the Income TaxAct for the Financial Year 2019-20.. 3. Pass such other order or orders as this Hon’ble court may deem fit andproper in the circumstances of the case.”

2.

In substance, the case of the petitioner as contended by its counsel is, despite filing replies to the notices issued by the respondents on 23.06.2021, 13.01.2023, 24.01.2023, 19.06.2025 and 17.07.2025 (as submitted yesterday, i.e., 28.07.2025), no response/order/decision is forthcoming. 3. Mr. Ruchir Bhatia, learned counsel appearing for the respondents states that if this being the only the grievance of the petitioner, the respondent shall consider the writ petition itself as a representation of the 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 05/08/2025 at 12:17:48

petitioner and decide the same by passing a reasoned order within a period of six weeks from today as an outer limit and communicate the decision thereof to the petitioner. The submission is taken on record. 4. The petition along with pending applications is disposed of.

V. KAMESWAR RAO, J

VINOD KUMAR, J JULY 29, 2025 tg

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 05/08/2025 at 12:17:48

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