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

Judgment text excerpt

$~12 * 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;” Signature Not Verified Digitally Signed By:RAM KUMAR Signing Date:20.05.2025 W.P.(C) 15336/2024 Page 1 of 5 12:36:40 2. The petitioner is a company incorporated in India and is a 100 percent subsidiary of Schneider France. During the previous year relevant to Assessment Year [AY] 2006-07, the petitioner was engaged in the business of manufacturing low voltage and medium voltage equipments – Air Circuit Breakers (ACB), Miniature Circuit Breakers, Moulded Case Circuit Breakers, RM 6, Contractors, Push Buttons and Ring Master units. The petitioner was also engaged in the distribution of imported electric equipments mainly for industrial use; repair and maintenance services; implementa