SIEGWERK INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 22(2), & ORS.

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W.P.(C)/11150/2026HC DelhiDLHC01035901202606 August 2026Bench: HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court refused to issue any sweeping directions to the Assessing Officer for the time-bound disposal of the rectification application. The Court reasoned that without quantifiable data regarding the pendency of assessments and the overall workload of the authority, it could not issue such broad directives. The Court suggested that the petitioner could file a separate application or representation for early disposal, which the AO would consider in accordance with the law. The writ petition was dismissed, and pending applications were disposed of.

What were the facts?

The petitioner, Siegwerk India Private Limited, filed a writ petition before the Delhi High Court challenging the delay in the disposal of its rectification application, which had been pending since October 31, 2025. The petitioner argued that a CBDT circular mandates Assessing Officers (AOs) to decide rectification applications within six months. The respondents were the Deputy Commissioner of Income-tax, Circle 22(2), and others. The High Court noted the petitioner's grievance regarding the pending application.

What were the issues?

1. Whether the High Court should issue a sweeping direction to the Assessing Officer to decide the petitioner's rectification application in a time-bound manner, considering the pendency of such applications and the work of the authority. Assessee's Contention: The petitioner argued that a CBDT circular directs AOs to decide rectification applications within six months and sought a time-bound disposal of its pending application. Revenue's Contention: The judgment does not record any specific arguments from the revenue.

AI-generated summary — verify with the full judgment below

$~133 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010359012026 + W.P.(C) 11150/2026 & CM APPL. 51654/2026 SIEGWERK INDIA PRIVATE LIMITED .....Petitioner Through: Mr. Manuj Sabharwal, Mr. Drona Negi and Mr. Manish Kumar, Advocates. versus DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 22(2), & ORS. .....Respondents Through: Mr. Sunil Agarwal, SSC with Ms. Monica Benjamin, Mr. Gibran Naushad, JSCs, Ms. Harshita Sharma, Mr. Adeeb Ahmad and Ms. Laiba Arif, Advocates. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA O R D E R % 06.08.2026 1. By way of the present writ petition, the petitioner has raised the grievance that the petitioner’s rectification application is pending since 31.10.2025. 2. Mr. Manuj Sabharwal, learned Counsel for the petitioner argued that a circular has been issued by the Central Board of Direct Taxes (hereinafter referred to as ‘CBDT’), directing the Assessing Officers (hereinafter referred to as ‘AO’) to decide rectification application within a period of six months. 3. Having heard learned Counsel for the petitioner, we are of the view that unless the quantifiable data about the pendency of the assessment and other 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 10/08/2026 at 12:03:53

work of an authority is before us, we cannot issue any sweeping direction to any authority to decide an application or matter in a time bound manner. 4. We, therefore, refuse to issue any such directions to the AO. The petitioner may, however, file an application/representation for early disposal. In case, any such application is filed, the same shall be considered by the AO, in accordance with law. 5. The present writ petition stands dismissed. Pending application also stand disposed of, accordingly. DINESH MEHTA, J. RAJNEESH KUMAR GUPTA, J. AUGUST 6, 2026/MR 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 10/08/2026 at 12:03:53

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