Legal Case Summary

Case Details
Case ID ea69e363-0058-45a1-a16a-1a3f7a29b6d8
Body View case body.
Case Number IT APPEAL NO. 1012 OF 2006
Decision Date Jul 04, 2006
Hearing Date
Decision The Tribunal ruled that the assessee was entitled to interest on the refund for the entire period claimed, from April 1, 2002, to July 19, 2004. The court found that the assessee had filed timely returns and addressed all technical objections raised by the department without causing any delays. The decision emphasized the responsibility of the department to not take advantage of the assessee's ignorance regarding their rights under the law. The appeal by the revenue was dismissed, upholding the Tribunal's decision which was found to be reasonable and not perverse, thus not giving rise to any substantial question of law.
Summary In the case of Director of Income-tax v. Mitsubishi Corporation, the Delhi High Court addressed the issue of interest on refunds under Section 244A of the Income Tax Act, 1961. The case revolved around the timely filing of revised returns by the assessee for the assessment years 2002-03 and 2003-04, claiming refunds for excess taxes withheld at source (TDS). The court highlighted that the assessee had complied with all legal requirements and filed the necessary documents in a timely manner. The Tribunal's acceptance of the assessee's claim for interest on the refund from April 1, 2002, until the refund was granted on July 19, 2004, was upheld. The decision reinforced the principle that the department should not exploit the ignorance of taxpayers regarding their rights and obligations. Overall, this case emphasizes the importance of timely actions by both the taxpayer and the tax authorities in matters of tax refunds and interest claims.
Court Delhi High Court
Entities Involved Not available
Judges MADAN B. LOKUR, VIPIN SANGHI
Lawyers Sanjeev Sabharwal
Petitioners Mitsubishi Corporation
Respondents Director of Income-tax, New Delhi
Citations 2007 SLD 4082 = (2007) 295 ITR 64, [2006] 155 TAXMAN 581 (DELHI)
Other Citations Not available
Laws Involved Income Tax Act, 1961
Sections 244A