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Delhi HC Stayed Demand Under Section 143(1) Due to Double Disallowance Error

Case Law Details

TaxGuru Citation
2026 taxguru.in 1380
Case Name
Portronics Digital Private Limited Vs ACIT (Delhi High Court)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2024-25
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Portronics Digital Private Limited Vs ACIT (Delhi High Court)

The petitioner challenged an intimation dated 14.12.2025 issued under Section 143(1) of the Income Tax Act, 1961 for Assessment Year 2024–25, raising a demand of ₹1.37 crore. The petitioner contended that expenses amounting to ₹4.26 crore had already been added back while filing the return, but despite furnishing a clarification in response to a notice dated 07.03.2025, the demand was raised without considering the reply, resulting in double disallowance. The Revenue submitted that the intimation was appealable but acknowledged that the issue arose due to a technical error in filling the relevant column in the return, which led to automated processing by the CPC. It was further stated that the issue could be resolved if the petitioner filed a rectification application with an amended return. An internal email from the Department indicated that online rectification after correcting the relevant schedules would resolve the double addition. In view of these submissions, the Delhi High Court disposed of the writ petition by directing the petitioner to file a rectification application with an amended return by 31.01.2026. The demand was ordered not to be enforced until disposal of the rectification, with consequential relief to follow as per law.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,835

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