UIPATH SRL vs. DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAX CIRCLE 3 1 1 & ORS.

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W.P.(C)/8987/2024HC DelhiDLHC01038074202404 July 2024Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA2 pages
AI SummaryPartly Allowed

What did the High Court hold?

The Delhi High Court recorded and accepted the statement made by the revenue's counsel. The revenue assured that all refunds payable to the petitioners, along with interest under Section 244A of the Income Tax Act, 1961, would be released within a period of three weeks from the date of the order. Consequently, the writ petitions were disposed of based on this assurance. The court did not explicitly decide on the correctness of the demand but implicitly addressed it by ensuring the release of refunds, which would likely resolve any dispute arising from an incorrect demand. No issue was expressly left undecided.

What were the facts?

The writ petitions were filed by UiPath SRL, the assessee, against the Deputy Commissioner of Income Tax and the Centralized Processing Centre, Bangalore, representing the revenue. The assessment year in question is 2021-22. The petitions challenge the non-release of refunds and the existence of an incorrectly exhibited demand. The procedural history involves the filing of these writ petitions before the Delhi High Court. The revenue, through its counsel, made a statement regarding the examination of the grievance and the release of refunds.

What were the issues?

1. Whether the assessee is entitled to the release of refunds for Assessment Year 2021-22? (Question of law and fact, concerning the right to refund under the Income Tax Act, 1961). 2. Whether the demand exhibited for Assessment Year 2021-22 is incorrect and should be deleted? (Question of law and fact, concerning the correctness of tax demands). Assessee's Contentions: The assessee's principal grievance is the non-release of refunds and the incorrect exhibition of a demand for AY 2021-22. Revenue's Contentions: The revenue, through its counsel, stated that the grievance has been examined and all refunds, along with interest under Section 244A of the Income Tax Act, 1961, would be released within three weeks.

Which sections of the Income-tax Act were involved?

Section 244A

AI-generated summary — verify with the full judgment below

Heard together (2 matters)

W.P.(C) 8987/2024
W.P.(C) 8988/2024

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

$~67&68 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8987/2024 UIPATH SRL

.....Petitioner Through: Mr. Sachit Jolly, Mr. Hansha Anand, Mr. Abhyrdaya Shankar Bajpai and Mr. Aditya Rathore, Advocates. versus DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAX CIRCLE 3 1 1 & ORS.

.....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC and Ms. Pratishtha Chaudhary and Mr. Naveen Kohila, Advocates. 68. + W.P.(C) 8988/2024 UIPATH SRL

.....Petitioner Through: Mr. Sachit Jolly, Mr. Hansha Anand, Mr. Abhyrdaya Shankar Bajpai and Mr. Aditya Rathore, Advocates. versus CENTRALIZED PROCESSING CENTRE BANGALORE AND ORS & ORS. .....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC and Ms. Pratishtha Chaudhary and Mr. Naveen Kohila, Advocates. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE RAVINDER DUDEJA O R D E R %

04.07.2024 CM APPL. 36709/2024 (Ex.) in W.P.(C) 8987/2024 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 04/07/2025 at 00:49:17

CM APPL. 36715/2024 (Ex.) in W.P.(C) 8988/2024 Allowed, subject to all just exceptions. Applications stand disposed of. W.P.(C) 8987/2024 & W.P.(C) 8988/2024 1. The principal grievance which is raised in these writ petitions pertains to the release of refunds and for a deletion of demand which according to the writ petitioners is incorrectly exhibited for Assessment Year 2021-22. 2. Mr. Aseem Chawla, learned counsel for respondents on instructions states that the aforesaid grievance has been duly examined and that all refunds payable to the petitioners alongwith interest under Section 244A of the Income Tax Act, 1961 shall be released within a period of three weeks from today. The statement so made is recorded and accepted. 3. The writ petitions stand disposed of. YASHWANT VARMA, J. RAVINDER DUDEJA, J. JULY 4, 2024/vp 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 04/07/2025 at 00:49:17

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