Virtusa Consulting Services Private Limited vs. Deputy Commissioner Of Income Tax

WP/8062/2026HC TelanganaGSTCNR HBHC01008521202630 June 2026Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA17 pages

For Petitioner: MS. ANANYA KAPOOR, REPRESENTING, SRI T PRADYOTHFor Respondent: MS. J SUNITHA (SR SC FOR INCOM TAX)

AI SummaryRemanded

Facts

A batch of writ petitions were filed by Virtusa Consulting Services Private Limited (as successor of Polaris Consulting and Services Limited) against the Deputy Commissioner of Income Tax and others. The petitioner's grievance was the inaction of the Income Tax Department in releasing refunds due to them. These refunds arose from orders passed by the Income Tax Appellate Tribunal (ITAT) or the High Court, and in some cases, matters were pending at the Transfer Pricing Officer (TPO) level requiring scrutiny before refund. The petitioner sought directions for the respondents to pass necessary orders and issue refunds with statutory interest for various Assessment Years (AYs) including 2012-13, 2006-07, 2013-14, 2003-04, and 2008-09, with specific amounts in dispute.

Held

The Court disposed of the batch of writ petitions. The primary issue was the delay and inaction by the Income Tax Department in releasing refunds due to the petitioner. The Court accepted the submission of the learned Standing Counsel for the Income Tax Department that the petitions could be disposed of with a direction to the respondents. Accordingly, the Court directed Respondent No. 1 to forthwith scrutinize the petitioner's claim for refunds. If the claims were found to be payable, the refund was to be made to the petitioner. The Court mandated that this entire exercise be concluded and the amount released within an outer limit of three months from the date of the order. Furthermore, the Court emphasized that during the processing of refunds, the authorities must ensure the calculation and computation of statutory interest payable on the said amounts in accordance with the relevant provisions. The assessing authority was also directed to consider any pending proceedings at the Transfer Pricing Officers' level while settling the refund amounts.

Key Issues

1. Whether the respondents have failed to act on the petitioner's claim for refunds arising from ITAT/High Court orders and TPO proceedings, thereby causing undue delay in the release of due amounts? 2. Whether the petitioner is entitled to the release of pending principal amounts of refunds along with up-to-date statutory interest under Section 244A of the Income Tax Act, 1961? Petitioner's Arguments: The petitioner argued that the respondents have been inactive in processing and releasing the refunds due to them, despite favorable orders from higher authorities like the ITAT and the High Court. They contended that the delay is causing financial prejudice and that they are entitled to the principal refund amounts along with statutory interest as per Section 244A of the Act. The petitioner provided calculation memos detailing the amounts due for various AYs. Respondents' Arguments: The learned Senior Standing Counsel for the Income Tax Department submitted that the writ petitions could be disposed of with a direction to the respondent No. 1 to scrutinize the petitioner's claim and, if found payable, to release the refund. They did not contest the petitioner's entitlement to scrutiny and potential refund.

Sections Cited

Section 244A

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

a3447 | IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (SPecial Original Jurisdiction) TUESDAY, THE THIRTIETH DAY OF JUNE TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA 7262 8062 9't60 9161 9364 AND 10968 0F WP.Nos.6224 6023 6104 726'.1 WP NO: 6224 oF 2026 004 4. Centralized Processing Karnataka 560500 Centre, lncome-tax Department, Bengaluru' Between: Virtusa Consulting Services Private Limited' (as a successor of, Polaris consulting And Services Limited) No.2O3, Manikonda lT Park, Raiendranagar Manda, RangareoOy' Hyderabad, Telangana' 500019 GST N9' 36AACCV6797LaZt cep. by its Authorized Representative vasu Pendyala' S/o. Pandu Pendyata, Agei about 55 years' No' 31-124' Ramakrishna Puram, Near nty -Station,-R K Puram, Malkajgiri' Hyderabad' Telangana - 500047 ...PETITIONER AND Deputy Commissioner of lncome Tax, Circle B('1 )' Signature Tow^ers', Sy' r.r"loii;l oi Konorprr, Sy. 37(P) of Kothaguda, opp Botanical Gardens' Serfingrrpaffy, R.R District, Hyderabad, Telangana 500084 Pr.Commissioneroflncomerax-2,SignatureTowers,Sy.No.6(P)of XonOrprr, Sy. 37(P) of Kothaguda, Opp Eotanical Gardens Serlingampally' R.R. District, Hyderabad, Telangana 500084 Deputy Commissioner of lncome Tax, DC/ACIT TP-3' 5th Floor' Aayakar B#;;",-dp"site LB Stadium, Basheer Bagh' Hyderabad' Telangana - 500 1 2 3 ...RESPONDENTS 2026 Petition under Article 226 ol lhe Constitution of lnrjia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 and or Article 227 of the Constitution of lndia, to direct the Respondents to pass the correct and necessary appeal effect order in accordance with law pursuant to CIT(A) order dated 2810612024 and iss re the refund due to the Petitioner for AY 2012-13 comprising of pending principal amount of Rs.2,98,94,932/- along with refund adjusted from AY 2014-15 amounting to Rs.6,34,36,520/- and upto-date statutory interest due under Section 2444 of the Act amounting to Rs.4,36,2'l ,83911 in a time bound manner. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J SUNITHA (SR SC FOR INCOM TAX) WP NO: 6023 OF 2026 Betwee n: Virtusa Consulting Services Private Limited, (as a successor of Polaris Consulting and Services Limited) No.203, lrlanikonde lT Park, Rajendranagar Manda. Rangareddy, Hyderabad, Telang;rna, 500019 GST No.:36AACCV6797L4ZE Rep. by its Authorizec Representative Vasu Pendyala, Sio. Pandu Pendyala, Aged about 55 years, Rlo. 31-124, Ramakrishna Puram, Near RIy Station, R K Puran, l\,4alkajgiri, Hyderabad, Telangana - 500047 ...PETITIONER AND 1. Deputy Commissioner of lncome Tax, Circle 8(1) Signature Towers, Sy. No.6(P) of Kondapur, Sy. 37(P) of Kothaguda, C)pp. Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax -2, Signature Towers. Sy. No. 6(P) of Koidapur, Sy. 37(P) of Kothaguda,Opp. Botanical Gardens Serlmgampally, R.R. District, Hyderabad, Telangana 500084 3. Centralized Processing Centre, lncome-tax Departmr..nt,Bengaluru, Karnataka 560500 ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 andtor Arlicle 227 of the Constitution of lndia, to direct the Respondents to issue the refund due to the Petitioner for AY 2006-07, comprising, of refund granted in subject AY pursuant to filing of return of lncome amounting to Rs.4,41,22,558/- along with up{o date statutory interest due under section 244A oI the Act calculated up-to December, 2025 amounting to Rs' 5,22,85 '231 ' in a time bound manner Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J SUNITHA (SR SC FOR INCOM TAX) WP NO : 6104 OF 2026 Between: AND Virtusa consulting Services Private Limited, (as a successor of Polaris Consulting it Services Limited) No.203, Mankonda lT Park' Rajendranagar It/andal, Rangareddy, Fiyderabad' Telangana, 500019 GST No..36AACCV6lbltqzi Rep. uy its Authorized Representative vasu p""Oyufu, S/o. Pandu Pendyala. Aged about 55 years' No 31'124' Ramakrishna Puram, Near Rty Statlon, R K Puram, Malkajgiri' Hyderabad' Telangana - 500047 ...PETITIONER Deputy Commissioner of lncome Tax Circle 8(1), Signature Towers' Sy' r.r"ioiFl of Kondapur, Sy. 37(P) of Kothaguda, op^p Botanical Gardens' Serlingampally, R.R. District, Hyderabad, Telangana 500084 PrCommissioneroflncomeTax2,signatureTowers,syNo6(P)of foiOapur, Sy. 37(P) of Kothaguda' Opp Botanical Gardens Serlmgampally' R.R. District, Hyderabad, Telangana 500084 Deputy Commissioner of lncome Tax, DC/ACIT TP-3' sth Floor' Aayakar B#;;", Opposite LB Stadium, Basheer Bagh, Hyderabad' Telangana - 500 1 2 3 004 4. Centralized Processing Centre, Karnataka 560500 lncome-tax DePartment, Bengaluru, ...RESPONDENTS Petition under Article 226 of the constitution of lnclia praying that in the circumstances stated in the affidavit filed therewith, the Higl' court may be pleased to issue a writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 and or Article 227 of the Constitut on of lndia, to direct the Respondents to pass the correct and necessary appeal effr:ct order in accordance with law pursuant to clT(A) order dated 28.06.2024 and issue the refund due to the Petitioner for AY 2013-14 comprising of pending principal amount of Rs.5,98,60,8591 and Rs.1 1,69,24,1601- against the refund adlustment of AY 20'l 5- 16 and AY 2004-05 along with up-to-date statutory interest (jue under Section 244A of the Act amounting to Rs. 9,76,57,7751-, tn a time bound mlnner. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 7261 OF 2026 Between: Virtusa Consulting Services Private Limited, (as a successor of Polaris Consulting and Services Limited) No.203, Manikondz lT Park, Rajendranagar Mandal, Rangareddy, Hyderabad, Telangana, 500019 GST No-:36AACCV6797L4ZE Rep. by its Authorizec Representative Vasu Pendyala, S/o. Pandu Pendyala, Aged about 55 years, No. 31-124, Ramakrishna Puram, Near Rly Station, R K Puran, Malkajgiri, Hyderabad, Telangana - 500047 ...PETITIONER AND 1 . Deputy Commissioner of lncome Tax, Circle 8(1 ) Signature Towers, Sy. No.6(P) of Kondapur, Sy. 37(P) of Kothaguda, Opp. Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax- 2, Signature l.owers, Sy. No. 6(P) of Kondapur, Sy 37(P) of Kothaguda, Opp. Botanical Sardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 3. Centralized Processing Centre, lncome{ax Department, Bengaluru, Karnataka 560500 ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 andtor Arlicle 227 of the Constitution of lndia, to direct the Respondents to pass the necessary and correct order on the Petitioner's giving effect application dated 13.08.2025 and to give effect to the Hon'ble High court's order dated 30.04.2025 in accordance with law and consequently issue the refund due to the Petrtioner for AY 2003-04 comprising of pending principal amount of Rs.86,93,9731 along with up{o-date statutory interest due under section 244A of the Act till date, in a time bound manner. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J SUNITHA (SR SC FOR INCOM TAX) WP NO:7262 OF 2026 Between: Virtusa Consulting Services Private Limited (as a successor of Polaris Consulting and Services Limited, No.203, I\/anikonda lT Park, Ra.iendranagar MandaL, Rangareddy, Hyderabad, Telangana, 5000 19 GST No..36AACCV6tgltqZt aep. by its Authorized Representative Vasu Pendyala, S/o. Pandu Pendyala' Aged about 55 years, No 31-124' Ramjkrishna Puram, Near Rly Station, R K Puram, Malkajgiri, Hyderabad, Telangana - 500047 AND ..,PETITIONER Deputy Commissioner of income Tax,, Circle B(1), Signature Towers, Sy No' 6(P) ;f Kondapur, Sy. 37(P) of Kothaguda, Opp Botanical Gardens' Seriingampally, R.R. District, Hyderabad, Telangana 500084 Pr. Commissioner of lncome Tax 2, Signature Towers, Sy No 6(P) of Koidapur, Sy. 37(P) of Kothaguda,0pp. Botanical Gardens Serlmgampally' R.R. District, Hyderabad, Telangana 500084 Centralized Processing Centre, lncome-tax Department, Bengaluru' Karnataka 560500 1 2 J ...RESPONDENTS Petition under Article 226 ol the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the Higl' court may be pleased to issue a writ in the nature of Mandamus or any other appropriate writ, order or direction under Article 226 andtor Article 227 of the Constitut on of lndia, to direct the Respondents to pass the correct and necessary appeal eff,sct order in accordance with law pursuant to High court order dated 04.o2.2021 and issue the consequential refund due to the Petitioner for AY 2011-12 amounting to Rs. 3,82,96,080 in a time bound manner Counsel for the Petitioner: MS. ANANYA KAPOOR' REPRESENTING SRI T PRADYOTH SRI T. PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 8062 OF 2026 Between: Virtusa Consulting Services Private Limited, (as a successor of Polaris Consulting And Services Limited) No.203, Manikonda lT Park, Rajendranagar Mandal, Rangareddy, Hyderabad, Telangana. 500019 GST No 36AACCV6797L4ZE Rep. by its Authorized Representative Vasu Pendyala, S/o. Pandu Pendyala, Aged about 55 years, Rlo. 31-124, Ramakrishna Puram, Near Rly Station, R K Puram, t\/alkajgiri, -lyderabad, Telangana - 500047 ...PETITIONER AND 1. Deputy Commissioner of lncome Tax, Circle 8(1). Signature Towers, Sy. No. 6(P) of Kondapur, Sy. 37(P) of Kothaguda, Cpp. Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax-2, Signature Towers, Sy. No. 6(P) of Kondapur, Sy. 37(P) of Kothaguda,0pp. Botanical Gardens Serlmgampally, R.R. District, Hyderabad, Telangana 500084 3. Centralized Processing Centre, lncometax Department, Bengaluru, Karnataka 560500 ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a Writ in the nature of l/andamus or any other appropriate writ, order or direction under Article 226 andlor Arlicle 227 of the Constitutlon of lndia, to direct the Respondents to pass the correct and necessary appeal effect order in accordance with law pursuant to ITAT order dated 10.05.2024 and issue the refund due to the Petitioner for A.Y. 2009-10 comprising of pending principal amount of Rs 6,03,37,047t- along with up{o-date statutory interest due under section 244A ol the Act and credit of other years refund, in a time bound manner Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 9160 0F 2026 Between: Virtusa consulting services Private Limited, (as a successor of Polaris ConsultingandServicesLimited)No'2O3,ManikondalTPark'Rajendranagar Mandal, Rangareddy, Hyderabad, Telangana, 500019 GST No ' 36AACCV6797L4ZE Rep. by its Auihorrzed Representative Vasu Pendyala, Sio Pandu Pendyala, Aged about 55 years, No. 31-124, Ramakrishna Puram, Near Rly Station, R K Puram' Malkajgiri, Hyderabad, Telangana - 500047 ...PETITIONER AND 1. Deputy Commissioner of lncome Tax, Circle B(1),, Signature Towers, Sy No 6(P) of KondaPur, SY SerlingampallY, R.R. Dis. 37(P) of Kothaguda, Opp. Botanical Gardens, trict, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax- 2, Signature Tcwers, Sy. No. 6(P) of Kondapur, Sy 37(P) of Kothaguda, Opp. Botanical SardensSerlmgampally, R.R. District, Hyderabad, Telangana 500084 3 centralized Processing Centre, lncome{ax Drlpartment' Bengaluru' Karnataka 560500 ...RESPONDENTS Petition under Article 226 of the Constrtution of lnlia praying that in the circumstances stated in the affrdavit filed therewith, the High Court may be pleased to issue a Writ in the nature of [\,4andamus or any other aopropriate writ, order or direction under Article 226 andlor Atticle 227 of the Constitujion of lndia, to direct the Respondents to pass the correct and necessary appeal eflect order in accordance with law pursuant to the High Court order dated 2311012018 lnd issue the refund due to the Petitioner for AY 2001-02 comprising of pending principal amount of Rs.31,85,6191 along with up{o-date statutory interest du€ under Section 244A of the Act in a time bound manner and to pass such other order or orders including costs of this Petition in favour of the Petitioner and against Respondents as this Honoruable Court may deem fit, just and proper in the circurnstances of the case. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 9161 OF 2026 Between: Virtusa Consulting Services Private Limited, (as a successor of Polaris Consulting and Services Limited) No.203, Manikond,r lT Park, Raiendranagar Mandal, Rangareddy, Hyderabad, Telangana 500019 GST No. 36AACCV6797L4ZE Rep. by its Authorized Representative Vasu Pendyala S/o. Pandu Pendyala, Aged about 55 years, No.31-124 Ramakrishna Pur;rn", Near Rly Station, R K Puram, Malkajgiri, Hyderabad, Telangana - 500047 ...PETITIONER AND 1. Deputy Commissioner of lncome Tax, Circle 8(1), S;ignature Towers, Sy. No. 6(P) of Kondapur, Sy. 37(P) of Kothaguda, C)pp. Botanical Gardens, Serlingampally, R,R. District, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax -2, Signature Towers, Sy' No 6(P) of Kondapur, Sy. 37(P) of Kothaguda,Opp. Botanical Gardens Serlmgampally, R.R. District, Hyderabad, Telangana 500084 3. Centralized Processing Centre, lncome-tax Department,Bengaluru, Karnataka 560500 ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a wflt in the nature of [\,4andamus or any other appropriate writ, order or direction under Article 226 andtor Atlicle 227 of the Constitution of lndia, to direct the Respondents to pass the correct and necessary appeal effect order in accordance with law pursuant to the High Court order dated 23l10l2Ol B and issue the refund due to the Petitioner for AY 2OO2-03 totalling to Rs.3,28,76,01 1l along with statutorily applicable interest due under Section 244A oI the Act, in a time bound manner and to pass such other order or orders including costs of this Petition in favour of the Petitioner and against Respondents as this Honble court may deem fit, just and proper in the circumstances of the case. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 9364 OF 2026 Between: Virtusa consulting Services Private Limited, (as a successor of Polaris Consulting and Services Limited) No.203, Manikonda lT Park, Rajendranagar tvlandal, Rangareddy, Hyderabad, Telangana, 500019 GST No ' 364ACCV6797L4ZE Rep. by its Authorized Representative Vasu Fendyala, S/o. Pandu Pendyala, Aged about 55 years, No 31-124' Ramakrishni Puram, Near Rly Station, R K Puram, Malkajgiri, Hyderabad, Telangana - 500047 AND ...PETITIONER 1. Deputy Commissioner of lncome Tax,, Circle 8(1), Si(lnature Towers, Sy. No' 6(P) of Kondapur, Sy. 37(P) of Kothaguda, Opp. Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 2. Deputy Commissioner of lncome-tax, DC/ACIT TP-3. 5th Floor, Aayakar Bhawan, Opposite LB Stadium, Basheer Bagh, Hyderabad, Telangana - 500 004 3. Pr. Commissioner of lncome Tax- 2,, Signature Towers, Sy. No. 6(P) of Kondapur, Sy. 37(P) of Kothaguda, Opp. Botanical Ciardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 4. Centralized Processing Centre,, lncome-tax Department, Bengaluru' Karnataka 560500 ...RESPONDENTS Petition under Article 226 of lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ in the nature of [Vlandamus or any other appropriate writ, order or direction under Article 226 andlor Arlicle 227 of the Constitulion of lndia, to direct the Respondents to pass the correct and necessary appeal efiect order in accordance with law pursuant to ITAT order dated 02.01 .2017 and issrre the refund due to the Petrtioner for A.Y. 2007-08, comprising of pending p-incipal amount of Rs 2,05,37,0171- along with statutorily applicable interest due on the same under Section 244A of the Act, as tabulated at paragraph 21 , in a time bound manner and to pass such other order or orders including costs of this Petition in favour of the Petitioner and against Respondents as this Hon'ble Cour. rray deem fit, just and proper in the circumstances of the case. Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX) WP NO: 10968 OF 2026 Between: Virtusa Consulting Services Private Limited, (as a successor of Polaris Consulting and Services Limited) No.203, Manikonda lT Park, Rajendranagar Mandal, Rangareddy, Hyderabad, Telangana, 500019 GST No. 36AACCV6797L4ZE Rep. by its Authorized Representative Vasu Pendyala, S/o. Pandu Pendyala, Aged about 55 years' No. 31-124, Ramakrishna Puram, Near Rty Station, R K Puram, t\/alkajgiri, Hyderabad, Telangana - 500047 ...PETITIONER AND 1. Deputy Commissioner of lncome Tax' Circle B(1), Signature Towers, Sy No' 6(P) of Kondapur, Sy. 37(P) of Kothaguda, Opp Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084 2. Pr. Commissioner of lncome Tax -2, Signature Towers, Sy. No. 6(P) of Kondapur, Sy. 37(P) of Kothaguda,0pp. Botanical Gardens, Serlingampally, R. R. District, Hyderabad, Telangana 500084 3. Deputy Commissioner of lncome tax, DC/ACIT TP-3, 5th Floor, Aayakar Bhawan, Opposite LB Stadium, Basheer Bagh' Hyderabad, Telangana - 500 004 4. Centralized Processing Centre, lncome-tax Department, Bengaluru, Karnataka 560500 ,..RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ in the nature of N/andamus or any other appropriate writ, order or direction under Article 226 andlor Arlicle 227 of the Constitution of lndia, to direct the Respondents to pass the necessary and correct order on the Petitioner's giving effect application dated 01 .07.2019 and to give effect to the Honble ITATs orders dated 30.08.20.13 and 04.10.2016 in accordance with law and dispose off the rectification application daled 23.12.2021 in accordance with law in a time bound manner and consequently issue the refund due to the Petitioner for AY 2008-09 comprising of pending principal amount of Rs. Rs. 4,68,59'789/- along with up{o- date statutory interest due under section 244A of the Act on the same, in a time bound manner Counsel for the Petitioner: MS. ANANYA KAPOOR, REPRESENTING SRI T PRADYOTH Counsel for the Respondents: MS. J. SUNITHA (SR SC FOR INCOM TAX)

The Court made the following: COMMON ORDER

IN TIIE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD THE HONOURABLE SRI JUSTICE P. SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA WRIT PETITION Nos.6224 6023 6LO4 726L 7262 ao62 9160, 91 6L.9364, 10968 of2026 DATE: 30.06.2026 Between: Virtl.tsa Consulting Sertices Prlaqte Limited ...Petitloner AND Deputg Commlssioner of Income Tox & others ,,.Respondents COMMON ORDER: (As per the Hon'bLe Si Justtce P. Sant Koshy) Heard Ms. Ananya Kapoor, learned counsel representing Mr. T. Pradyoth, learned counsel appearing for the petitioner and Ms. J. Sunitha, learned Senior Standing Counsel for Income Tax appearing for the respondents 2, These are a batch of writ petitions which are being preferred before this Court where the grievalce of the petitioner is only to the extent of the inaction on the part of the respondent/ Income Tax Department in not releasing the refunds payable to the petitioner arising out of either the orders

2of 4 PsK, / & NNR, / - L\P Nc.6221 of 2a26 & Batch passed by the learned Income Tax Appellate Tribunal or that by the High Court. In a couple of other iases, the matters are pending at the Transfer Pricing Officers (TPO) lt:r'e1 rn,'here again the refund is to be scrutinized ald paid to the petitioners'

Learned counsel for the petitioner Lras placed the calculation memo across the Bench and the sarre is reproduced hereunder: pending (in rNR) (trcludins int€rest) in INR (factoring inter adjustment) App€al has 31.85.619 I.O1,94,326 3,28,16,411 3,28,16,O71 86,93,913 86,93,973 4,4\,22,558 4,4t,22,5\a ).,a\,31,417 5,79,84,644 4,64,59,789 5,12,88,763 6,A3,37,441 22,99,24,451 3,82,96,080 3,82,95,080 23 10.2018 FC No No NO No No NO 2l 10.2018 tlc aY 2001 02 aY 2002 03 AY 2003 04 AY 2005 07 AY 2011 12 9160/2A26 9 161/2026 1261/2026 bo2t/2a26 ao62/1A26 1)62/2026 30 r4.2025 H' 2a )4 102f AO NO Ye5 AY 2007 08 9364/2A26 aY 2008 09 ta968/2026 AY 2009 10 04 10.2016 IlII 08 12 2021 Y€s HC (Normal) and ITAT and Crr(A)for proceed ngs 04 l2:021 uc 2t )1 ZO23 matters) 02 11 2017 l1^ T 10 )5 2024 -

24.06.

2024 crTlA) 9 33.31.451 2,9a,94.937 aY 2012 13 No 17,67,85,019 6104/2026 AY 2013-14 s,98,60,8s9 34,31,04,383 Total 3 of 4 PsK,/&NNR,/ WP No.6224 of 2025 €t Batch 6224/2026 28.06-)024 - crT(A) No 4. Today when the matter is taken up for hearing, the learned Standing Counsel for the Income Tax Department submits that these writ petitions can be disposed of today with a direction to respondent No. 1 to scrutinize the claim of the petitioner and if found payable the same shall be refunded to the petitioner.

In view of the submission made by the learned Standing Counsel for Income Tax Department, this Court deems it proper to direct respondent No.l to forthwith scrutinize the claim of the petitioner arrd if found payable, the refund be made to the petitioner. Let the entire exercise be concluded and release the amount within an outer limit of three (3) months from today'

Needless to mention that when the refunds are to be processed, the authorities shali also ensure calculation and computation of the interest payable on the said amount accordance with the statutory provisions accordingly. 1n

4ot4 PSK, / &NNR, / - W' l! :.6224 of 2026 & Batch

The assessing authority shall also look into the aspect as to whether any of the proceedings are still pertding at the level of the Transfer Pricing Officers, the same shorllcl also be taken care of in the course of settling the refund amounts payable to the petitioner. 8, Accordingly, these Writ Petitions are disposed of. There sha1l be no order as to costs. As a sequel, misceilaneous petitions per:dtng if any, shall stand closed M. OSMAN ALI BAIG ASSISTANT REGISTRAR //// i I - ECTION OFFICER To, TJ TKS l}^(^

Deputy Commissioner of lncome Tax, Circle 8(1). Signature Towers, Sy. No.6(P) of Kondapur, Sy. 37(P) of Kothaguda, C)pp. Botanical Gardens, Serlingampally, R.R. District, Hyderabad, Telangana 500084

Pr. Commissioner cf Income Tax 2, Signature T:nrers. Sy. No. 6(P) of Koidapur, Sy. 37(P) of Kothaguda, Opp. Botanical 3ardens Serlmgampally. R.R. District, Hyderabad, Telangana 500084

Deputy Commissioner of lncome Tax, DC/ACIT TP-3, 5th Floor, Aayakar Bhawan, Opposite LB Stadium, Basheer Bagh. Hyd,:rabad, Telangana - 500 004

Centralized Processing Centre, lncome-tax [)epartment, Bengaluru, Karnataka 560500

One CC to Sri T. Pradyoth, Advocate [OPUC] 6 One CC to N/s. J. Sunitha (SR SC for INCOM TAX) IOPUC]

Two CD Copies

HIGH COURT DATED: 3010612026 COMMON ORDER WP. Nos.6224, 6023, 6104, 7 261, 7 262, 8062, 91 60, 9161, 9364 AND 10968 0F 2026 iHc >t A ( o? )c Sn lUi ?0t + cl t// 1-,7 t DISPOSING OF THE ALL WRIT PETITIONS WITHOUT GOSTS fdAq, !!:?!tY)2-l/ 29 +\,6

Reproduced from the public record of the Telangana High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.