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

PDF · subscribers
W.P.(C)/8078/2024HC DelhiDLHC01033649202421 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 revenue informed the court that a manual refund of Rs.19,62,30,473/- had been processed and issued via cheque dated 22.09.2025. This was acknowledged by the petitioner's counsel. For AY 2014-15, the revenue stated that a rectification order had determined a refund of Rs.6,68,90,519/-, but it was pending due to technical glitches with the CPC-ITR team. The revenue requested six weeks' time to process this refund, which the court granted. The court disposed of the petitions with liberty to the petitioner to revive them if the refund for AY 2014-15 was not processed/paid within the granted time. No specific finding was made on the validity of the initial adjustments challenged by the petitioner, as the matter was resolved by the subsequent processing of refunds.

What were the facts?

The petitioner, G4S Secure Solutions India Pvt Ltd, filed two writ petitions before the Delhi High Court. WP(C) 8052/2024 concerned Assessment Year (AY) 2021-22, challenging an intimation dated 17.10.2022 (signed 09.05.2023) under Section 143(1) of the Income Tax Act, 1961, which adjusted refunds of Rs. 6,48,99,253/- and Rs. 11,18,87,930/- against an alleged irrecoverable demand for AY 2013-14. It also challenged consequent challans dated 11.10.2023. WP(C) 8078/2024 concerned AY 2022-23, challenging an intimation dated 02.03.2023 under Section 143(1) that adjusted a refund of Rs. 6,08,09,563/- against an alleged irrecoverable demand for AY 2014-15, and consequent challans dated 04.03.2023. The petitioner sought quashing of these intimations and challans and a direction for the refund along with interest.

What were the issues?

1. Whether the adjustment of refunds for AY 2021-22 against an alleged irrecoverable demand for AY 2013-14, as per the intimation under Section 143(1) and subsequent challans, is valid? (Question of law and fact, concerning Section 143(1) and refund adjustment principles). 2. Whether the adjustment of refund for AY 2022-23 against an alleged irrecoverable demand for AY 2014-15, as per the intimation under Section 143(1) and subsequent challans, is valid? (Question of law and fact, concerning Section 143(1) and refund adjustment principles). Assessee's Contention: The petitioner sought quashing of the intimations and challans and release of the full refund with interest. The specific arguments regarding the validity of the adjustments were not detailed in the provided text, but the prayers indicate a dispute over the adjustment of refunds against prior year demands. Revenue's Contention: For AY 2013-14, the revenue stated that manual refund processing had been completed and a refund of Rs.19,62,30,473/- was issued via cheque dated 22.09.2025. For AY 2014-15, the revenue acknowledged a rectification order dated 13.11.2024 determining a refund of Rs.6,68,90,519/-, but stated the refund was pending with the CPC-ITR team due to technical glitches, with an incident ticket raised on 06.11.2025. The revenue sought six weeks' time to process this refund.

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 15:27:59

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 15:27:59

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 15:27:59

More judgments on Section 244A

All 1,186 judgments and leading authorities on Section 244A →

Recent GST High Court judgments

Search GST case law →