M/S SIREZ LIMITED vs UNION OF INDIA & ORS.

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 04.11.2025 Judgment delivered on: 08.12.2025 Judgment uploaded on: As per Digital Signature~ + W.P.(C) 405/2024 M/S SIREZ LIMITED .....Petitioner versus UNION OF INDIA & ORS. .....Respondents Advocates who appeared in this case For the Petitioner : Mr. Santosh Kumar, Sr. Adv. with Mr. Medhurendra Sharma and Mr. Rajiv Ranjan Mishra, Advocates. For the Respondents : Ms. Bakshi Vinita, SPC for UOI. Mr. Vipul Agrawal, SSC, Ms. Sakshi Sehawal, Mr. Akshat Singh, JSCs and Mr. Gaoraang Ranjan and Ms. Harshita Kotru, Advocates. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON’BLE MS. JUSTICE MADHU JAIN JUDGMENT V. KAMESWAR RAO , J. 1. This petition has been filed with the following prayers: “i) Set aside the order dated 23.11.2023 passed by the respondent no.1. ii) Issue Writ of Mandamus/order/direction whereby directing the respondents to reimburse/release TDS Amount (Rs.19,73,540). iii) Cost of this petition.” 2. The facts as borne out from the petition are that the petitioner Signature Not Verified Signed By:PRADEEP WP(C) No.405/2024 Page 1 of 15 SHARMA Signing Date:08.12.2025 16:15:12 company was incorporated on 15.06.2005 and is engaged in the work of digital marketing, content marketing, digital media planning, social media marketing, mobile app development (android and iOS), website development & inbound marketing. The petitioner did not file its Return of Income (ITR) for the Assessment Years (AY) 2018-19, even after the extended period upto 31.10.2018. The petitioner filed its ITR on 20.09.2021 after a delay of 30 months. Thereafter, the petitioner filed an application vide letter dated 20.09.2021 under Section 119(2)(b) of the Income Tax Act, 1961 (the Act) for condonation of delay in filing the ITR and cl