SCHNEIDER ELECTRIC INDIA PVT LTD vs DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 22 2 NEW DELHI & ANR.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision: 09.05.2025 W.P.(C) 15336/2024 SCHNEIDER ELECTRIC INDIA PVT LTD .....Petitioner Through: Mr. Sachit Jolly, Sr. Advocate with Mr. Mansha Anand, Mr. Abhyudaya Shankar Bajpai, Mr. Aditya Rathore and Mr. Sohum Dua, Advocates. versus DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 22 2 NEW DELHI & ANR. .....Respondents Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kumar, Mr. Gibran Naushad and Mr. Rishabh Nangia, JSCs for Income Tax Department. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (Oral) 1. The petitioner has filed the present petition, inter alia, praying as under: - “issue a writ in the nature of mandamus or any other appropriate writ, order or direction declaring that the assessment proceedings for AY 2005-06 (sic) [AY 2006-07] are barred by limitation therefore, direct the Respondents to grant refund of taxes paid/ deposited/adjusted in the case of Petitioner for AY 2005-06 (sic) [AY 2006-07], along with applicable interest under Section 244A(1) and 244A(1A) of the Act, as per law;” 2. The petitioner is a company incorporated in India and is a 100 percent subsidiary of Schneider Fra