Disposed¶20

Portronics Digital Private Limited v. Assistant Commissioner of Income-Tax Circle 19(1), Delhi & Ors.

Delhi HC16 Jan 2026W.P.(C)/606/2026

Case brief

AI extract

What is this about?

Section 143(1) intimation; Income Tax Act, 1961; AY 2024-25; CPC double addition; double disallowance; schedule BP/PART A-OI; prima facie adjustment notice; rectification application; amended ITR; refund; non-enforcement of demand; Portronics Digital Private Limited v. ACIT Circle 19(1), Delhi; Delhi High Court; W.P.(C) 606/2026.

What did the court decide?

Petitioner directed to file a rectification application with amendment in the Income Tax Return by 31.01.2026; upon compliance, respondents to pass consequential order and make refund in accordance with law; enforcement of the demand stayed until disposal of the rectification application. ¶20

Portronics Digital Private Limited Vs Assistant Commissioner of… — Income Tax | Delhi HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the intimation dated 14.12.2025 under Section 143(1) of the Income Tax Act, 1961 raising a demand of Rs.1.37 crores for assessment year 2024-25 was erroneous, having resulted in a double disallowance/double addition despite the petitioner having itself added back expenses in its return and furnished clarification dated 01.04.2025.

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Court's answer

On the basis of instructions received from the Income Tax Department, the writ petition and pending application are disposed of by directing the petitioner to file a rectification application and amendment in its Income Tax Return; if done by 31.01.2026, the respondents shall pass a consequential order and make the refund in accordance with law.

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Ratio / Principle

The demand raised against the petitioner shall not be enforced until the petitioner's rectification application is disposed of.

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Detailed headnote1 paragraphs

Income Tax – Intimation under Section 143(1) of the Income Tax Act, 1961 for AY 2024-25 raising demand of Rs.1.37 crores – Alleged double addition/disallowance: petitioner had itself added back expenses of Rs.4,26,06,170/- in its return; CPC sought clarification by notice dated 07.03.2025; clarification furnished on 01.04.2025 was not considered – Respondents' Senior Standing Counsel acknowledged the error at petitioner's end was technical and placed on record departmental e-mail advising filing of online rectification after correcting schedule BP/PART A-OI so that the double addition would be resolved – Writ petition disposed of directing petitioner to file rectification application and amended ITR by 31.01.2026, failing which directions lapse; respondents to pass consequential order and make refund in accordance with law; demand not to be enforced until rectification application is disposed of.

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$~33

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 606/2026, CM APPL.2979/2026

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PORTRONICS DIGITAL PRIVATE LIMITED .....Petitioner

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Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari and Mr. Drona Negi, Advs.

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versus

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ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE 19(1), DELHI & ORS. .....Respondents Through: Mr. Ruchir Bhatia, SSC and Ms. Lopamudra Mahapatra, Adv.

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CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

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O R D E R

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% 16.01.2026

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By way of present writ petition, the petitioner has challenged the intimation dated 14.12.2025, issued under Section 143(1) of the Income Tax Act, 1961 ( hereinafter referred to as ‘the Act of 1961’ ) for assessment year 2024-25, whereby a demand of Rs.1.37 crores has been raised against the petitioner.

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Learned counsel for the petitioner submitted that he himself had added back the expenses to the extent of Rs.4,26,06,170/- which were reflected in its profit and loss account, when it furnished the income tax return. However, the Assessing Officer, Centralized Processing Center sent a notice dated 07.03.2025 to the petitioner seeking clarification. In response thereto, the petitioner furnished the clarification on 01.04.2025 but without

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This is a digitally signed order.

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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 20/01/2026 at 12:54:17

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considering the same, the aforesaid demand has been raised, which on the face of it, is erroneous. Because it has resulted in double disallowance.

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Mr. Ruchir Bhatia, learned Senior Standing Counsel while submitting that the impugned intimation order is appealable before the Commissioner of Income Tax (Appeals), however, admitted that the error at petitioner’s end was technical and he might be justified in his stand. But since, instead of furnishing the details in applicable column, he had filled in the details in another column, the CPC which processes/assesses return online or through computers could take its cognisanse.

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He further submitted that in case a rectification application with amended ITR is filed, the requisite process shall be undertaken.

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Mr. Bhatia in this regard, placed for perusal of the Court, an e-mail which he has received from the Income Tax Department. Relevant paragraph of which reads as under:

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“The assessee may be informed to file online rectification after making necessary corrections in schedule BP/PART A-OI as indicated above through e-filing portal, so that the issue of double addition in this case will get resolved. PDF of prima facie adjustment notice, intimation under 143(1) issued to assessee, return of income/audit report filed enclosed herewith for ready reference. PW to open intimation u/s. 143(1) is aafcp.”

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In view of the instructions given to Mr. Bhatia, the present writ petition along with pending application is disposed of by directing the petitioner to file a rectification application and amendment in the Income Tax Return. In case, the needful is done by 31.01.2026, the respondents shall pass consequential order and make refund in accordance with law.

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The demand raised against the petitioner shall not be enforced until

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This is a digitally signed order.

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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 20/01/2026 at 12:54:17

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the petitioner’s rectification application is disposed of.

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DINESH MEHTA, J

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VINOD KUMAR, J

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JANUARY 16, 2026/ ss

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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 20/01/2026 at 12:54:17

Portronics Digital Private Limited v. Assistant Commissioner of Income-Tax Circle 19(1), Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Portronics Digital Private Limited v. Assistant Commissioner of Income-Tax Circle 19(1), Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

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