Yashita Finance Private Limited Vs PCIT (Delhi High Court)
Summary: The Delhi High Court considered a petition concerning the non-payment of a refund determined under Form No. 4 issued under the Direct Tax Vivad Se Vishwas Scheme, 2024. Form No. 4 was issued in favour of the petitioner on 14.10.2025, determining a refund of Rs. 1,78,32,616/-. The petitioner contended that, while Section 92(2) of the Scheme requires an applicant/assessee to deposit the amount determined in Form 4 within 15 days, the respondents should similarly refund the amount within 15 days or a reasonable period.
On 17.07.2026, the Court directed the Jurisdictional Assessing Officer to explain the inordinate delay and show cause why interest for the intervening period should not be paid to the petitioner and recovered personally from him. In response, the Assistant Commissioner of Income Tax stated that the refund could only be processed through the Income Tax Business Application (ITBA) system, that the requisite functionality for processing orders giving effect under DTVSVS, 2024 was unavailable from October 2025 to March 2026 and became operational only in April 2026, and that no module reflected refunds to be processed under the Scheme. It was also submitted that the Assessing Officer was engaged in statutory time-barring proceedings under Sections 148 and 148A of the Income-tax Act, 1961 during April to June 2026. According to the affidavit, after the assessee’s letter dated 01.07.2026, the refund was processed on 06.07.2026.
