ALLIED CONCEPTS INDIA PVT LTD. vs. THE PRINCIPAL COMMISSIONER (PCIT-1) & ORS.

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W.P.(C)/9258/2026HC DelhiDLHC01029371202601 October 2026Bench: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE DR. JUSTICE ADITI CHOUDHARY2 pages
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What did the High Court hold?

The Delhi High Court observed that the petitioner's substantial grievance, which was the refund, had been redressed. Consequently, the writ proceedings were closed and the petition was disposed of. However, the Court granted the petitioner liberty to pursue the issue of incorrect interest calculation. The petitioner was permitted to file an appropriate application under Section 154 of the Income Tax Act, 1961, or make a representation before the Assessing Officer within four weeks, detailing their calculation of the interest. The Assessing Officer was directed to consider this application or representation in accordance with the law and pass a reasoned order within three months of its receipt. The petitioner's right to challenge any subsequent consequential orders was also preserved.

What were the facts?

The petitioner, Allied Concepts India Pvt Ltd., filed a writ petition before the Delhi High Court challenging an order or action by the Principal Commissioner (PCIT-1) & Ors. The core of the petitioner's grievance was related to the refund of taxes and the calculation of interest thereon. During the pendency of the writ petition, the petitioner received the refund. However, the petitioner contended that the interest paid on the refund was not calculated correctly. The High Court noted that the substantial grievance of the petitioner had been addressed by the refund.

What were the issues?

1. Whether the interest paid on the refund to the petitioner has been correctly calculated, as per the provisions of the Income Tax Act, 1961? Assessee's Contention: The petitioner argued that while the refund itself had been received, the interest calculated and paid on that refund was incorrect. The petitioner sought a proper calculation and payment of the due interest. Revenue's Contention: The judgment does not record any specific contentions from the revenue regarding the calculation of interest. The focus of the revenue's participation, as reflected in the order, was in response to the petitioner's submission that the refund had been received.

Which sections of the Income-tax Act were involved?

Section 154

AI-generated summary — verify with the full judgment below

$~7 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010293712026 + W.P.(C) 9258/2026 & CM APPLs. 43353/2026, 43354/2026, 68569/2026

ALLIED CONCEPTS INDIA PVT LTD.

.....Petitioner

Through: Mr. Utkarsh Mathur, Adv.

versus

THE PRINCIPAL COMMISSIONER (PCIT-1) & ORS. .....Respondents Through: Mr. Anurag Ojha, SSC with Ms. Hemlata Rawat & Mr. VK Saxena, JSCs.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE DR. JUSTICE ADITI CHOUDHARY

O R D E R %

01.10.2026

1.

Learned counsel for the petitioner submitted that during the pendency of the present writ petition, the petitioner has received the refund, however, the interest thereupon has not been correctly calculated/paid to the petitioner. 2. Since the petitioner’s substantial grievance has been redressed, writ proceedings are closed; the petition stands disposed of. Pending application(s), if any, also stand disposed of. 3. The petitioner, however, shall be free to move an appropriate application under Section 154 of the Income Tax Act, 1961 or make a representation before the Assessing Officer, giving his calculation on interest within a period of four weeks from today. The Assessing Officer 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 05/10/2026 at 11:14:57

shall consider the same, in accordance with law and pass a reasoned order within a period of three months from the receipt of such application or representation. 4. The petitioner’s right to take remedies against any consequential orders shall remain reserved.

DINESH MEHTA, J.

ADITI CHOUDHARY, J. OCTOBER 1, 2026/p’ma 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 05/10/2026 at 11:14:57

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