COURSERA, INC. vs. INCOME-TAX OFFICER CIRCLE INT TAX 1(2)(1), DELHI & ORS.

PDF · subscribers
W.P.(C)/9186/2025HC DelhiDLHC01040475202507 July 2025Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA2 pages
AI SummaryAllowed

What did the High Court hold?

The Delhi High Court allowed the writ petition filed by Coursera, Inc. The Court directed the Revenue to pay the applicable statutory interest under Section 244A(1) of the Income Tax Act, 1961, for the delayed period of refund disbursal. The Court acknowledged that there was no dispute regarding the petitioner's entitlement to interest on the delayed payment. The Revenue was instructed to make the payment as expeditiously as possible, preferably within twelve weeks from the date of the order. The Court did not leave any issue undecided.

What were the facts?

The petitioner, Coursera, Inc., filed its return of income for Assessment Year 2024-25 on October 23, 2024, declaring a total income of ₹45,30,190/- and claiming a refund of ₹16,56,69,530/-. An intimation under Section 143(1) of the Income Tax Act, 1961, was issued on November 20, 2024, determining the refund due as ₹16,95,39,570/-. This refund amount was received by the petitioner on February 21, 2025. The petitioner contended that the refund disbursal was delayed and claimed statutory interest under Section 244A(1) of the Act for the period from December 2024 to February 2025.

What were the issues?

1. Whether the petitioner is entitled to statutory interest under Section 244A(1) of the Income Tax Act, 1961, for the delayed period of refund disbursal. Assessee's Contention: The petitioner argued that it is entitled to statutory interest under Section 244A(1) of the Income Tax Act, 1961, for the period from December 2024 to February 2025, as the refund determined by the intimation dated November 20, 2024, was disbursed on February 21, 2025, indicating a delay. Revenue's Contention: The Revenue did not record any specific arguments against the claim for interest. The judgment notes that there is no dispute that the petitioner would be entitled to interest on the delayed payment.

Which sections of the Income-tax Act were involved?

Section 244A(1),Section 143(1)

AI-generated summary — verify with the full judgment below

$~43 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 9186/2025 & CM APPL. 38981/2025 COURSERA, INC. .....Petitioner Through: Mr Manuj Sabharwal, Mr Drona Negi and Mr Devvrat Tiwari, Advocates. versus INCOME-TAX OFFICER CIRCLE INT TAX 1(2)(1), DELHI & ORS. .....Respondents Through: Mr. Debesh Panda, SSC Ms. Zehra Khan, Mr. Vikramaditya Singh, JSCs Ms Anauntta Shankar and Ms Ravicha Sharma, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 07.07.2025 1. Issue notice. The learned counsel for the Revenue accepts notice. 2. The petitioner has filed the present petition, inter alia, praying as under:- “Issue a writ in the nature of mandamus or other appropriate writ(s), order(s) directing the respondents to credit the applicable statutory interest under s. 244A(1) of the Incometax Act, 1961 (“Act”) for the period from December 2024 till February 2025 on the refund determined vide intimation dated 20.11.2024 (Annexure P-1).” 3. The petitioner has filed its original return of income on 23.10.2024 in respect of the Assessment Year [AY] 2024-25 declaring a total income of ₹45,30,190/- and claiming the refund of ₹16,56,69,530/-. 4. The intimation under Section 143(1) of the Income Tax Act, 1961 was communicated on 20.11.2024 determining the amount of refund due as 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 09/07/2025 at 11:45:20

₹16,95,39,570/-. The said amount was also received on 21.02.2025. The petitioner claims that it is entitled to interest for the period of three months as the disbursal of the said amount has been delayed. 5. There is no dispute that the petitioner would be entitled to interest on the delayed payment. 6. In view of the above, the present petition is allowed and the Revenue is directed to pay the interest for the delayed period, that is, till the date of the payment as expeditiously as possible, and preferably within the period of twelve weeks from date. The pending application is also disposed of. VIBHU BAKHRU, J TEJAS KARIA, J JULY 07, 2025 M Click here to check corrigendum, if any 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 09/07/2025 at 11:45:20

Recent GST High Court judgments

Search GST case law →