MANPOWER GROUP SERVICES INDIA PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 & ORS.

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W.P.(C)/5728/2026HC DelhiDLHC01018121202613 May 2026Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryRemanded

What did the High Court hold?

The High Court noted that the respondents had remitted the refund amount of Rs. 26,81,80,796/- to the petitioner, and the petitioner acknowledged receiving the full amount along with interest. However, the petitioner raised a specific grievance regarding a discrepancy in the calculation of the interest. The Court found that the petitioner's primary grievance concerning the refund itself had been redressed. Therefore, the Court granted liberty to the petitioner to move an application before the Assessing Officer (AO) under Section 154 of the Income Tax Act, 1961, for rectification of the interest calculation. The AO is directed to consider and decide this application in accordance with the law within three months of receiving it. The writ petition was disposed of on this basis, with no decision on the merits of the interest calculation dispute.

What were the facts?

The petitioner, Manpower Group Services India Private Limited, filed a writ petition before the Delhi High Court challenging an action or order by the Assistant Commissioner of Income Tax, Central Circle-2 & Ors. The assessment year(s) are not specified. The dispute involved a refund amount of Rs. 26,81,80,796/-. The respondents submitted that the due refund, including interest, had been remitted to the petitioner. The petitioner acknowledged receiving the full amount but raised a grievance regarding a discrepancy in the calculation of the interest component. The High Court noted that the petitioner's primary grievance had been redressed.

What were the issues?

1. Whether the petitioner's grievance regarding the refund of Rs. 26,81,80,796/- has been satisfactorily redressed. Assessee's Contention: The petitioner argued that while the entire refund amount along with interest has been received, there is a discrepancy in the calculation of the interest. The petitioner seeks rectification of this calculation. Revenue's Contention: The respondents submitted that the due refund amounting to Rs. 26,81,80,796/- has been remitted to the petitioner, and therefore, the petitioner's grievance has been appropriately redressed. The revenue did not address the specific claim of interest calculation discrepancy.

Which sections of the Income-tax Act were involved?

Section 154

AI-generated summary — verify with the full judgment below

$~1 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 5728/2026 CM APPL. 28160/2026

MANPOWER GROUP SERVICES INDIA PRIVATE LIMITED .....Petitioner

Through: Ms. Ananya Kapoor, Adv.

versus

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 & ORS.

.....Respondents Through: Mr. Sunil Agarwal, SSC with Ms. Monica Benjamin, JSC, Mr. Gibran Naushad, JSC, Mr. Rohit Chakraborty & Ms. Nancy Jain, Advs.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE OM PRAKASH SHUKLA

O R D E R %

13.05.2026 1. Ms. Monica Benjamin, learned Junior Standing Counsel for the respondents, at the outset submitted that the due refund amounting to Rs.26,81,80,796/- has been remitted to the petitioner and therefore, the petitioner’s grievance has been appropriately redressed. 2. At this juncture, Ms. Ananya Kapoor, learned counsel for the petitioner submitted that though entire amount along with interest has been received, but there is a discrepancy in the calculation of the interest. 3. By closing the proceedings as grievances of the petitioner has been satisfactorily redressed, we grant liberty to the petitioner to move an application before the Assessing Officer (AO) under Section 154 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 15/05/2026 at 12:45:59

Income Tax Act, 1961. 4. The petitioner shall file an application giving out calculation of interest, which shall be considered and decided by the AO in accordance with law, within a period of three months from receiving the application. 5. The writ petition is disposed of along with pending application.

DINESH MEHTA, J

OM PRAKASH SHUKLA, J MAY 13, 2026/sr

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 15/05/2026 at 12:45:59

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