M/S REAL TIME DATA SERVICES PRIVATE LIMITED vs PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-7 & ANR.

Judgment text excerpt

$~4 to 6 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of decision: 13thFebruary, 2026. + W.P.(C) 959/2024 & CM APPL. 3939/2024 + W.P.(C) 960/2024 & CM APPL. 3941/2024 + W.P.(C) 961/2024 & CM APPL. 3943/2024 M/S REAL TIME DATA SERVICES PRIVATE LIMITED .....Petitioner Through: Mr. Satyalipsu Ray and Mr. Prasana Kumar Dash, Advs. versus PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-7 & ANR. .....Respondents Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kr & Mr. Rishab Nagia, JSC CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT DINESH MEHTA, J. (ORAL) 1. All the writ petitions involve a common question of law, however with some difference in facts and therefore, they are being decided conjointly. The facts of W.P.(C) 959/2024 pertaining to assessment year 2020-21 are however, taken for consideration. 2. The petitioner failed to file Form No. 67 as required under Rule 128 of Signature Not Verified Digitally Signed By:NAVEEN KUMAR W.P.(C) 959/2024 & other connected matters Page 1 of 5 Signing Date:18.02.2026 14:49:45 the Income Tax Rules, 1962 (hereinafter referred to as ‘Rules of 1962’) within the prescribed time limit. It was only on receipt of intimation/order under section 143(1)(a) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act of 1961’) the assessee realised that the credit of the tax deducted on its foreign receipts has not been given and therefore, it moved an application under Section 154 of the Act of 1961 before the Assessing Officer (hereinafter referred to as ‘AO’) for rectification. According to the petitioner, the same has not been dealt with/decided by the AO. 3. In the meantime, the petitioner moved an application for revision under Section 264 of the Act of 1961 before the Principal Commissioner of Income Tax (