CADENCE DESIGN SYSTEMS (INDIA) PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 4(2), DELHI & ORS.

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W.P.(C)/1173/2025HC DelhiDLHC01003691202507 February 2025Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE CHIEF JUSTICE DEVENDRA KUMAR UPADHYAYA2 pages
AI SummaryRemanded

What did the High Court hold?

The Delhi High Court did not decide the merits of the case. The Court noted the submissions made by the revenue regarding the calculation and credit of interest under Section 244A for AY 2009-10 and the withholding of refund under Section 245 for AY 2010-11. The Court directed the revenue to place on record a copy of the intimation/order, if passed, under Section 245 of the Act. The case was adjourned for further hearing. No finding was reached on the correctness of the calculations or the justification for withholding the refund. The operative direction was to list the case for further proceedings and for the revenue to produce specific documentation.

What were the facts?

The petitioner, Cadence Design Systems (India) Private Limited, filed a writ petition before the Delhi High Court. The respondents, represented by the Deputy Commissioner of Income-Tax, informed the Court that an order for Assessment Year 2009-10 had been passed on 06.10.2026, calculating interest under Section 244A of the Income Tax Act, 1961, and determining an amount of Rs. 2,14,52,900/- payable to the petitioner. This amount was stated to have been credited to the petitioner's account. Regarding Assessment Year 2010-11, the refund was withheld by invoking Section 245 of the Act, and the petitioner's authorized representative was informed. The petitioner's counsel stated they had no information regarding the credit or withholding of refunds.

What were the issues?

1. Whether the respondents have correctly calculated and credited the interest payable to the petitioner under Section 244A of the Income Tax Act, 1961, for Assessment Year 2009-10? 2. Whether the withholding of the refund for Assessment Year 2010-11 by invoking Section 245 of the Income Tax Act, 1961, is legally justified? Assessee's Contentions: The petitioner's counsel stated that the petitioner had no information regarding the credit of the refund for AY 2009-10 or the withholding of the refund for AY 2010-11. No specific legal arguments or reliance on authorities were recorded for the petitioner at this stage. Revenue's Contentions: The revenue, through its counsel, submitted that an order under Section 244A had been passed for AY 2009-10, calculating interest of Rs. 2,14,52,900/-, which has been credited. For AY 2010-11, the refund has been withheld under Section 245, and the assessee's representative was informed.

Which sections of the Income-tax Act were involved?

Section 244A,Section 245

AI-generated summary — verify with the full judgment below

$~1 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010036912025 + W.P.(C) 1173/2025

CADENCE DESIGN SYSTEMS (INDIA) PRIVATE LIMITED .....Petitioner Through: Mr. Manuj Sabharwal, Mr. Drona Negi, Mr. Raghav Arora & Mr. Manish Kumar, Advs.

versus

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 4(2), DELHI & 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 %

07.10.2026 CM APPL. 33142/2026 1. Mr. Anurag Ojha, learned Senior Standing Counsel on instructions submitted that on 06.10.2026, the Assessing Officer had passed an order and calculated applicable interest under Section 244A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) and determined an amount of Rs.2,14,52,900/- payable to the petitioner for the Assessment Year 2009-10. He submitted that as per his instructions, the requisite amount has been credited in petitioner’s account. 2. He added that so far as refund for Assessment Year 2010-11 is 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 12/10/2026 at 11:27:21

concerned, the same has been withheld invoking provisions of Section 245 of the Act of 1961 and assessee’s Chartered Accountant/authorised representative has been duly informed about the same. 3. Mr. Manuj Sabharwal, learned counsel for the petitioner submitted that his client has no information about the amount if credited or if the refund has been withheld. 4. List this case on 28.10.2026. 5. Mr. Anurag Ojha, learned Senior Standing Counsel for the respondents to place on record, a copy of the intimation/order (if passed) under Section 245 of the Act of 1961.

DINESH MEHTA, J.

ADITI CHOUDHARY, J. OCTOBER 7, 2026/sid

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 12/10/2026 at 11:27:21

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