MUFG BANK LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX & ORS.

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W.P.(C)/7835/2023HC DelhiDLHC01001960202214 January 2026Bench: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryDismissed

What did the High Court hold?

The Delhi High Court held that the petitions have become infructuous. This decision was based on the submission by the learned proxy counsel for the respondent that the Assessing Officer had passed rectification orders on January 7, 2026, for AY 1996-97 and AY 2001-02. These orders accepted the petitioner's contentions and calculated the refund, including interest under Sections 244A and 244A(1A) of the Income Tax Act, 1961. Consequently, the court dismissed both petitions as having been resolved. The court directed the respondents to pay the applicable refund amount to the petitioner within 30 days. It also provided a recourse for the petitioner to file a rectification application or seek revival of the petition if any grievance subsisted.

What were the facts?

The petitioner, MUFG Bank Ltd., filed two writ petitions before the Delhi High Court challenging actions of the Assistant Commissioner of Income Tax. The petitions concerned Assessment Year (AY) 1996-97 and AY 2001-02. The Assessing Officer, Assistant Commissioner of Income Tax Circle 2(2)(1) International Taxes, New Delhi, passed two rectification orders on January 7, 2026. These orders accepted the petitioner's contentions and calculated the refund due, including interest under Sections 244A and 244A(1A) of the Income Tax Act, 1961. Copies of these orders were presented to the court.

What were the issues?

1. Whether the petitioner's grievance regarding the calculation of refund for AY 1996-97 and AY 2001-02 stands resolved by the rectification orders passed by the Assessing Officer? The assessee (petitioner) contended that their grievance would be resolved if the refund was correctly calculated and paid. The revenue (respondent) argued that the rectification orders dated January 7, 2026, have accepted the petitioner's contentions and calculated the refund, thereby resolving the issue. The revenue also stated that the refund includes applicable interest under Section 244A and 244A(1A) of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 244A,Section 244A(1A)

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

W.P.(C) 7835/2023
W.P.(C) 7842/2023

Read from the judgment's own cause title. This page is filed under one of them.

$~20 & 21 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 7835/2023 MUFG BANK LTD .....Petitioner Through: Mr. Hiten Thakkar, Mr. Nikhil Ranja, Advs. versus ASSISTANT COMMISSIONER OF INCOME TAX & ORS. .....Respondent Through: Ms. Delphina Singhlai, Adv. 21 + W.P.(C) 7842/2023 MUFG BANK LTD .....Petitioner Through: Mr. Hiten Thakkar, Mr. Nikhil Ranja, Advs. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1) AND ORS. .....Respondents Through: Ms Delphina Singhlai, Adv. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

14.01.2026 1. Ms Delphina Singhlai, learned proxy counsel appearing for Mr. Debesh Panda, learned Senior Standing Counsel, at the outset submits that the respondent-Assessing Officer (Deputy Commissioner of Income Tax 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 19/01/2026 at 13:08:14

Circle 2(2)(1) International Taxes), New Delhi has passed two rectification orders dated 07.01.2026 for Assessment Year (hereinafter referred to as ‘AY’) 1996-97 and AY 2001-02, and accepted the petitioner’s contention and has calculated the refund for the subject years. Copies of the orders dated 07.01.2026 have been produced for perusal of the court, which are taken on record. 2. She further submits that in view of the aforesaid orders passed by the Assessing Officer and calculation of refund payable to the petitioner, which includes applicable interest under Section 244A and 244A(1A) of the Income Tax Act, 1961, petitioner’s grievance stands resolved. 3. In view of the aforesaid statement made by learned counsel for respondent, both these petitions are dismissed as having become infructuous. 4. The respondents are directed to refund/pay the applicable refund amount to the petitioner, in its bank account (if not already paid) as early as possible, preferably within a period of 30 days. 5. In case any of petitioner’s grievance still subsists, it shall be free to move rectification application before the Assessing Officer within a period of 30 days from today or move an application for revival of the present petition, which shall be considered in accordance with law. DINESH MEHTA, J VINOD KUMAR, J JANUARY 14, 2026/dd 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 19/01/2026 at 13:08:14

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