Clix Capital Services Private Limited Vs DCIT (Delhi High Court)
Summary: The Delhi High Court disposed of the writ petition filed by Clix Capital Services Private Limited, as successor to Clix Finance India Private Limited, after the Department informed the Court that the Assessing Officer had undertaken the requisite exercise and, by a manual order dated 18.08.2026, calculated an amount of Rs.20,33,42,656/- as payable to the petitioner. The Assessing Officer had recently joined on 13.08.2026. The Department submitted that although there had been substantial delay, the delay arose because the company’s legal status and name had changed multiple times pursuant to mergers and amalgamations, requiring tax deducted details and assessment orders standing in the names of various companies to be verified and reconciled. The Department assured the Court that the calculated amount would be credited to the petitioner’s account within two weeks.
Senior Counsel for the petitioner pointed out that there was a small error in the refund amount shown as payable. Since the petitioner’s grievance had substantially been redressed, the High Court did not consider it necessary to examine that discrepancy at that stage. Instead, it directed the Assessing Officer, Mr. Nirdesh Gangwar, to meet the petitioner’s representative on 31.08.2026 at a time convenient to him. The purpose of the meeting was to permit the representative to explain the discrepancy, facilitate verification of the record and address issues arising from the intimation under Section 245 of the Income Tax Act, 1961 concerning the proposed withholding/adjustment of refund.
The Court accordingly disposed of the petition while expressly reserving the petitioner’s rights to pursue appropriate remedies concerning calculation of the refund and interest. It further clarified that, if necessary, the petitioner would remain free to seek revival of the writ petition and/or appropriate directions. The pending application was also disposed of.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
1. Mr. Indruj Singh Rai, learned Senior Standing Counsel for Department informed that on 18.08.2026, the respondent-Assessing Officer, who has recently joined (on 13.08.2026) has undertaken the requisite exercise and passed a manual order on 18.08.2026 and calculated an amount of Rs. 20,33,42,656/- payable to the petitioner.
2. While inviting the court’s attention towards the affidavit of the AO which has been filed pursuant to our order of previous date, Mr. Rai submitted that although the delay was substantial, it was caused because of the fact that the company’s legal status changed multiple times and its name also changed on account of mergers and amalgamations, due to which, the details of tax deducted and assessment orders in the name of various companies were to be verified and reconciled. He assured that now the amount has been calculated and the same will be credited within two weeks in the petitioner’s account.
3. While complimenting the officer (who has joined recently) for the efforts he has taken, Mr. Jolly, learned Senior Counsel, pointed out that there is a small error in the amount of the refund shown to have been payable to the petitioner, qua which, we do not deem necessary to dilate upon, at this juncture.
4. While disposing of the petition as petitioner’s grievance in substance has been redressed, we direct the Assessing Officer-Mr. Nirdesh Gangwar, to meet the representative of the petitioner-company on 31.08.2026 at any time as per his convenience, so that the representative can explain the discrepancy, and also facilitate the verification of the record and address the issues arising out of the intimation under Section 245 of the Income Tax Act of 1961, for the proposed withholding/adjustment of refund.
5. With these observations, the petition stands disposed of.
6. Needless to observe that petitioner’s rights to take up its remedy in relation to the calculation of refund/interest shall stand reserved and in case of necessity, the petitioner shall be free to apply for revival of the writ petition and /or for appropriate direction.
7. Pending application stands disposed of.
