Facts of the Case

The present writ petitions were filed by the petitioner, PeopleStrong Technologies Private Limited, seeking directions to the Respondent (Assistant Commissioner of Income Tax) to credit refunds arising from excess deduction of tax at source (TDS) for Assessment Years 2017–18 and 2018–19 into its bank account, along with applicable interest.

During the pendency of the proceedings, it was submitted by the petitioner’s counsel that the refund amounts due for the relevant assessment years had already been received.

Issues Involved

  1. Whether the petitioner was entitled to issuance of directions for credit of TDS refund along with interest.
  2. Whether the writ petitions survive after receipt of the refund amount during the pendency of proceedings.

Petitioner’s Arguments

  • The petitioner contended that excess tax had been deducted at source for AY 2017–18 and 2018–19.
  • Despite entitlement, the refund had not been credited by the Income Tax Department.
  • The petitioner sought judicial intervention for immediate release of the refund along with interest accrued till date.

Respondent’s Arguments

  • During the course of hearing, it was indicated that the refund due to the petitioner had already been processed and credited.
  • Therefore, no further adjudication was required in the matter.

Court’s Findings / Order

  • The Hon’ble Delhi High Court noted the submission made by the petitioner’s counsel that the refunds for the relevant assessment years had been received.
  • In light of this development, the Court held that the grievance of the petitioner stood satisfied.
  • Accordingly, the writ petitions were disposed of as satisfied.

Important Clarification

  • The Court did not adjudicate on the merits of delay or entitlement to interest, as the principal relief had already been granted during the pendency of proceedings.
  • The disposal reflects that writ jurisdiction may not be invoked further once the cause of action ceases to exist.

Sections Involved

  • Income Tax Act, 1961
    • Section 199 – Credit for TDS
    • Section 237 – Refund of excess tax
    • Section 244A – Interest on refunds
  • Article 226 of the Constitution of India (Writ Jurisdiction)

Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2020:DHC:3885-DB/MMH12112020CW86832020_154005.pdf

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