G4S SECURE SOLUTIONS INDIA PVT LTD vs. DEPUTY DIRECTOR OF INCOME TAX CPC BANGALORE & ORS.

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W.P.(C)/8052/2024HC DelhiDLHC01033623202421 November 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR3 pages
AI SummaryRemanded

What did the High Court hold?

The Delhi High Court disposed of both petitions based on the submissions made by the revenue. For AY 2013-14, the court noted that the manual refund had been processed and issued to the petitioner, which was acknowledged by the petitioner's counsel. Therefore, the grievance concerning this assessment year was resolved. For AY 2014-15, the court granted the revenue six weeks' time to process the refund, as requested by the revenue's counsel due to pending technical issues with the CPC-ITR team. The court also granted liberty to the petitioner to revive the petition if the refund was not processed or paid within the stipulated time. No specific finding was made on the validity of the adjustments under Section 143(1) as the matter was resolved procedurally.

What were the facts?

The assessee, G4S Secure Solutions India Pvt Ltd, filed two writ petitions before the Delhi High Court challenging intimations issued under Section 143(1) of the Income Tax Act, 1961. In W.P.(C) 8052/2024, the assessee challenged an intimation dated 17.10.2022 (digitally signed on 09.05.2023) for AY 2021-22, where refunds totaling Rs. 17,67,87,183/- were adjusted against an alleged irrecoverable demand for AY 2013-14. In W.P.(C) 8078/2024, the assessee challenged an intimation dated 02.03.2023 for AY 2022-23, where a refund of Rs. 6,08,09,563/- was adjusted against an alleged irrecoverable demand for AY 2014-15. The petitions also sought quashing of consequent challans and a direction for the release of refunds with interest.

What were the issues?

1. Whether the adjustment of refunds for AY 2021-22 against the alleged irrecoverable demand for AY 2013-14, as per the intimation dated 17.10.2022, is valid under Section 143(1) of the Income Tax Act, 1961? 2. Whether the adjustment of refund for AY 2022-23 against the alleged irrecoverable demand for AY 2014-15, as per the intimation dated 02.03.2023, is valid under Section 143(1) of the Income Tax Act, 1961? Assessee's Contention: The assessee sought quashing of the intimations and challans, and a direction for the release of refunds with interest, implying the adjustments were erroneous. Revenue's Contention: For AY 2013-14, the revenue stated that a manual refund of Rs. 19,62,30,473/- had been processed and issued. For AY 2014-15, the revenue submitted that a rectification order dated 13.11.2024 determined a refund of Rs. 6,68,90,519/-, but it was pending due to technical glitches with the CPC-ITR team, requesting six weeks' time for processing.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 244A

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

W.P.(C) 8052/2024
W.P.(C) 8078/2024

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

$~5 & 6 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8052/2024 + W.P.(C) 8078/2024 G4S SECURE SOLUTIONS INDIA PVT LTD .....Petitioner Through: Mr. Sachit Jolly, Sr. Adv. with Ms Mansha Anand, Mr. Abhyudaya Shankar Bajpai, Mr Sohun Dua, Ms. Manvi, Mr. Ghunaim Siddiqui and Ms Ankita Prakash, Advs. versus DEPUTY DIRECTOR OF INCOME TAX CPC BANGALORE & ORS. .....Respondent Through: Mr. Abhishek Maratha, Sr. Standing Counsel, Mr. Apoorv Agarwal, Mr. Parth Samwal, Jr. SCs, Ms Nupur Sharma, Mr. Gaurav Singh, Mr. Bhanukaran Singh Jodha, Ms Muskaan Goel, Ms Sweta Mandal, and Mr. Himanshu Gaur, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

21.11.2025 1. These two petitions have been filed with the following prayers: W.P.(C) 8052/2024 “a) Writ of certiorari or an order seeking quashing of the intimation dated 17.10.2022 (digitally signed on 09.05.2023) issued by Respondent No.1 under Section 143(1) of the Act for the AY 2021-22 to the extent it adjusted refund of Rs. 6,48,99,253/- and Rs. 11,18,87,930/- against the irrecoverable demand for the AY 2013-14; 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 27/11/2025 at 15:28:02

b) Writ of certiorari or an order seeking quashing the consequent Challan(s) issued by Respondent No.1 on 11.10.2023 adjusting the refund of Rs. 6,48,99,253/- and Rs. 11,18,87,930/- against the irrecoverable demand for the A.Y. 2013-14; c) Writ of mandamus or an order directing the Respondents to issue a refund of Rs. 17,67,87,183/- along with interest under Section 244A computed till date of actual payment to be released to the Petitioner forthwith; d) Pass any other order(s) as this Hon'ble Court may deem to be fit and more appropriate in the facts and circumstances of the case.” W.P.(C) 8078/2024 “a) Writ of certiorari or an order seeking quashing of the Intimation dated 02.03.2023 issued by Respondent No. 1 under Section 143(1) of the Act for the AY 2022-23 to the extent it adjusts refund of Rs. 6,08,09,563/- against the irrecoverable demand for the AY 2014-15; b) Writ of certiorari or an order seeking quashing the consequent challan issued by Respondent No.1 on 04.03.2023 adjusting the refund of Rs.6,08,09,563/- against the irrecoverable demand for the A.Y. 2014-15; c) Writ of mandamus or an order directing the Respondents to issue a refund of Rs. 6,08,09,563/- along with interest under Section 244A computed till date of actual payment to be released to the Petitioner forthwith; d) Pass any other order(s) as this Hon'ble Court may deem to be fit and more appropriate in the facts and circumstances of the case.” 2. Both the petitions have been filed for identical prayers, but for different Assessment Years i.e. Assessment Years 2013-14 and 2014-15. 3. We have been informed by Mr. Abhishek Maratha SSC that he has instructions to state that for the Assessment Year 2013-14, manual refund has been processed and refund of Rs.19,62,30,473/- has been issued vide cheque dated 22.09.2025. This position is also acknowledged by the counsel appearing for the petitioner. 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 27/11/2025 at 15:28:02

4.

Insofar as the Assessment Year 2014-15 is concerned, the instructions are in the following manner : “For AY-2014-15, rectification order dated 13.11.2024 was passed determining refund of Rs.6,68,90,519/-. On perusal of records, it is seen that the fund is pending with CPC-ITR team due to some technical glitches. In this regard, ticket vide incident no. 3102468 was raised on 06.11.2025 (Annex-B), however resolution of the issue is still pending at the end of CPC-ITR. Accordingly, it is submitted that the refund will be issued soon. Kindly allow the 6(six) weeks’ time for processing of refund.” 5. Mr. Maratha SSC states that six weeks be granted to process the refund as sought for the AY-2014-15. Accordingly, we grant six weeks’ time to the respondents to process the refund and take further action thereafter. 6. With the above, we dispose of the petitions. 7. Liberty is granted to the petitioner to revive the petition in the eventuality the refund is not processed/paid, by filing an application. V. KAMESWAR RAO, J VINOD KUMAR, J NOVEMBER 21, 2025 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 27/11/2025 at 15:28:02

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