M/S MITSUI ENGINEEGIN & SHIP.C vs THE ASST. DIRECTOR OF INCOME T

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 23rd February, 2026 W.P.(C) 6708/2005 M/S MITSUI ENGINEEGIN & SHIP.C .....Petitioner Through: Mr. Rajiv Tyagi, Adv. versus THE ASST. DIRECTOR OF INCOME T .....Respondent Through: Mr. Siddhartha Sinha, SSC with Ms. Easha Gurung, JSC. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (ORAL) 1. By way of the instant writ petition, the petitioner has challenged the order of the Director of Income Tax, International Taxation, New Delhi dated 20.01.2005 whereby petitioner’s application under Section 154 of the Income Tax Act for additional interest under Section 244(1A) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) has been dismissed. 2. Learned counsel for the petitioner submitted that the reasoning of impugned order rejecting the petitioner’s application for interest was based upon the judgment of Bombay High Court rendered in the case of Sandvik Asia Ltd v. Commissioner of Income Tax-1 reported in (2004) 267 ITR 78 3. Having heard learned counsel for the parties and considering the fact that the judgment passed by the Bombay High Court in the case of S