M/S SMEC INDIA (P.) LTD. vs PRINCIPAL COMMISSIONER OF INCOME TAX - 8

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 23.01.2025 W.P.(C) 9969/2019 M/S SMEC INDIA (P.) LTD. .....Petitioner Through: Mr. Ved Jain, Mr. Nischay Kantoor, Ms. Soniya Dodeja, Mr. Divyansh Dubey and Mr. Govind Gupta, Advs. versus PRINCIPAL COMMISSIONER OF INCOME TAX – 8 .....Respondent Through: Mr. Debesh Panda, SSC along with Ms. Zehra Khan, JSC, Mr. Vikramaditya Singh, JSC, Mr. K. Sri Aditya, Adv and Ms. Anauntta Shankar, Adv. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR JUDGMENT YASHWANT VARMA, J. (Oral) 1. The writ petitioner impugns the order passed by the Principal Commissioner dated 25 March 2019 and in terms of which it has proceeded to dismiss an application that had been instituted by the petitioner purporting to be under Section 264 of the Income Tax Act, W.P.(C) 9969/2019 1. 2. The dispute itself arose in the context of an amount of INR 4,75,00,000/- which was paid by the petitioner on account of reimbursement of expenses incurred by its Associate Enterprise and on which it had not deducted tax at source. According to the writ petitioner, it had at the time of furnishing its Return of Income 2 for the co