PORTRONICS DIGITAL PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE 19(1), DELHI & ORS.

PDF · subscribers
W.P.(C)/606/2026HC DelhiDLHC01001117202616 January 2026Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA3 pages
AI SummaryRemanded

What did the High Court hold?

The Delhi High Court disposed of the writ petition by directing the petitioner to file a rectification application and amend its Income Tax Return. The Court noted the revenue's submission that the error was technical, arising from the petitioner incorrectly filling in details in a column. The revenue indicated that the CPC's online processing system could not account for this error, leading to the demand. The Court accepted the revenue's suggestion that filing a rectification application with necessary corrections in the relevant schedules (BP/PART A-OI) would resolve the issue of double addition. The Court ordered that if the rectification is done by 31.01.2026, the respondents shall pass a consequential order and make any refund due in accordance with law. The demand raised against the petitioner shall not be enforced until the rectification application is disposed of. The Court did not decide on the merits of the demand itself but provided a procedural remedy.

What were the facts?

The petitioner, Portronics Digital Private Limited, has filed a writ petition challenging an intimation dated 14.12.2025, issued under Section 143(1) of the Income Tax Act, 1961, for assessment year 2024-25. This intimation raised a demand of Rs. 1.37 crores. The petitioner claims to have voluntarily added back expenses of Rs. 4,26,06,170/- in its income tax return. Subsequently, the Assessing Officer, Centralized Processing Center (CPC), issued a notice seeking clarification. Despite the petitioner providing a clarification on 01.04.2025, the demand was raised, allegedly resulting in a double disallowance. The revenue acknowledged a technical error on the petitioner's part in furnishing details in an incorrect column, which the CPC, being a computer-based system, could not process correctly.

What were the issues?

1. Whether the intimation dated 14.12.2025, issued under Section 143(1) of the Income Tax Act, 1961, raising a demand of Rs. 1.37 crores for assessment year 2024-25, is erroneous due to a double disallowance, despite the assessee voluntarily adding back certain expenses. Assessee's Contention: The petitioner argued that the demand raised is erroneous as it results in a double disallowance, despite the petitioner having voluntarily added back expenses of Rs. 4,26,06,170/- and provided clarification to the CPC. The petitioner relied on the fact that the error was technical and the demand was on the face of it erroneous. Revenue's Contention: The revenue submitted that the impugned intimation order is appealable before the Commissioner of Income Tax (Appeals). However, the revenue admitted that the error at the petitioner's end was technical, stemming from furnishing details in an incorrect column, which the CPC could not process. The revenue suggested that filing a rectification application with an amended ITR would resolve the issue.

Which sections of the Income-tax Act were involved?

Section 143(1)

AI-generated summary — verify with the full judgment below

$~33 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 606/2026, CM APPL.2979/2026 PORTRONICS DIGITAL PRIVATE LIMITED .....Petitioner Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari and Mr. Drona Negi, Advs. versus ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE 19(1), DELHI & ORS. .....Respondents Through: Mr. Ruchir Bhatia, SSC and Ms. Lopamudra Mahapatra, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

16.01.2026 1. By way of present writ petition, the petitioner has challenged the intimation dated 14.12.2025, issued under Section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) for assessment year 2024-25, whereby a demand of Rs.1.37 crores has been raised against the petitioner. 2. Learned counsel for the petitioner submitted that he himself had added back the expenses to the extent of Rs.4,26,06,170/- which were reflected in its profit and loss account, when it furnished the income tax return. However, the Assessing Officer, Centralized Processing Center sent a notice dated 07.03.2025 to the petitioner seeking clarification. In response thereto, the petitioner furnished the clarification on 01.04.2025 but without 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 20/01/2026 at 12:54:17

considering the same, the aforesaid demand has been raised, which on the face of it, is erroneous. Because it has resulted in double disallowance. 3. Mr. Ruchir Bhatia, learned Senior Standing Counsel while submitting that the impugned intimation order is appealable before the Commissioner of Income Tax (Appeals), however, admitted that the error at petitioner’s end was technical and he might be justified in his stand. But since, instead of furnishing the details in applicable column, he had filled in the details in another column, the CPC which processes/assesses return online or through computers could take its cognisanse. 4. He further submitted that in case a rectification application with amended ITR is filed, the requisite process shall be undertaken. 5. Mr. Bhatia in this regard, placed for perusal of the Court, an e-mail which he has received from the Income Tax Department. Relevant paragraph of which reads as under: “The assessee may be informed to file online rectification after making necessary corrections in schedule BP/PART A-OI as indicated above through e-filing portal, so that the issue of double addition in this case will get resolved. PDF of prima facie adjustment notice, intimation under 143(1) issued to assessee, return of income/audit report filed enclosed herewith for ready reference. PW to open intimation u/s. 143(1) is aafcp.” 6. In view of the instructions given to Mr. Bhatia, the present writ petition along with pending application is disposed of by directing the petitioner to file a rectification application and amendment in the Income Tax Return. In case, the needful is done by 31.01.2026, the respondents shall pass consequential order and make refund in accordance with law. 7. The demand raised against the petitioner shall not be enforced until 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 20/01/2026 at 12:54:17

the petitioner’s rectification application is disposed of. DINESH MEHTA, J VINOD KUMAR, J JANUARY 16, 2026/ss 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 20/01/2026 at 12:54:17

Recent GST High Court judgments

Search GST case law →