MANOJ CHAUHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX 5 & ANR.

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W.P.(C)/11984/2025HC DelhiDLHC01055261202508 August 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 observed that the petitioner had filed a fresh rectification application under Section 154 of the Income Tax Act, 1961, on 22.04.2025, addressed to the Jurisdictional Assessing Officer (JAO). The Court directed that this application, dated 22.04.2025, shall be decided by the JAO in accordance with the law. The Court did not delve into the merits of the TDS credit claim or the rectification of the intimation. The operative direction was to ensure the pending application is adjudicated by the appropriate authority. The petition was disposed of with this observation, leaving the substantive issues to be decided by the JAO.

What were the facts?

The petitioner, Manoj Chauhan, filed a writ petition before the Delhi High Court seeking a mandamus directing the respondents to allow the TDS credit of Rs. 3,43,319 for AY 2018-19, which was deducted in the name of late Shri Chaman Lal Chauhan. The petitioner also sought a direction to rectify an intimation dated 25.02.2020 issued under Section 154 of the Income Tax Act, 1961. An earlier rectification application filed on 21.01.2020 was rejected by the Centralised Processing Centre (CPC). The petitioner then filed a fresh rectification application on 22.04.2025, along with relevant documents, addressed to the Jurisdictional Assessing Officer (JAO).

What were the issues?

1. Whether the petitioner is entitled to a writ of mandamus directing the respondents to allow the TDS credit of Rs. 3,43,319 for AY 2018-19, deducted in the name of late Shri Chaman Lal Chauhan? (Question of law and fact, concerning the allowance of TDS credit). 2. Whether the respondents should be directed to rectify the intimation dated 25.02.2020 issued under Section 154 of the Income Tax Act, 1961? (Question of law and fact, concerning rectification proceedings). Assessee's Contention: The petitioner argued that a fresh rectification application under Section 154 of the Income Tax Act, 1961, was filed on 22.04.2025, along with relevant documents, addressed to the Jurisdictional Assessing Officer (JAO). The petitioner sought a decision on this application. Revenue's Contention: The judgment does not record any specific arguments from the revenue's side regarding the merits of the TDS credit or the rectification application. The revenue was represented by Standing Counsel and Junior Standing Counsel.

Which sections of the Income-tax Act were involved?

Section 154

AI-generated summary — verify with the full judgment below

$~18 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 11984/2025 MANOJ CHAUHAN .....Petitioner Through: Mr Dev Raj Sharma and Mr Sarthak, Advocates. versus PRINCIPAL COMMISSIONER OF INCOME TAX 5 & ANR. .....Respondent Through: Mr Shlok Chandra, SSC, Ms Naincy Jain and Ms Madhavi Shukla, JSCs Mr Ujjwal Jain, and Mr Dhananjay, Advocates CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 08.08.2025 CM APPL. 48857/2025(Exemption) 1. Exemption is allowed, subject to all just exceptions. 2. The application stands disposed of. W.P.(C) 11984/2025 3. This petition has been filed with the following prayers: “(A) Issue a writ of mandamus or any other appropriate writ, order or direction, directing the Respondents to allow the TDS credit of Rs.3,43,319, which was deducted in the name of late Shri Chaman Lal Chauhan, for AY 2018–19; (B) Direct the Respondents to rectify the intimation dated 25.02.20200 issued under Section 154 of the Income Tax Act, 1961;” 4. In fact, the petitioner is seeking a decision on the rectification 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 12/08/2025 at 13:05:56

application filed on 22.04.2025. It may be stated here that earlier a rectification application was filed on 21.01.2020 which has been rejected by the Centralised Processing Centre (CPC). 5. The learned counsel for the petitioner submits that a fresh rectification application under Section 154 of the Income Tax Act, 1961 has been filed on 22.04.2025 along with the relevant documents addressed to the Jurisdictional Assessing Officer (JAO). 6. If that be so, the application dated 22.04.2025 shall be decided by the JAO in accordance with law. 7. The petition stands disposed of with the aforesaid observation. V. KAMESWAR RAO, J VINOD KUMAR, J AUGUST 08, 2025 RT 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 12/08/2025 at 13:05:56

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