High Court for the State of Telangana · Procedural orders and remands
Sahrudaya Health Care Private Limited v. Director of Income Tax (CPC-TR) & Ors.
W.P. No. 39496/2022 ·
Refund-adjustment writ withdrawn with liberty to approach respondents about an interest-calculation error.
1. FACTS OF THE CASE
Sahrudaya Health Care Pvt Ltd’s WP 39496/2022 challenged adjustment of a Rs.6,14,54,400 refund for AY 2021-22 against AYs 2014-15 and 2017-18, and withholding of Rs.12,43,04,410 for AY 2020-21 against AYs 2014-15 and 2018-19. These were allegations and reliefs in the prayer.
2. DISCUSSION BY THE COURT
At the hearing, counsel on instructions sought withdrawal with liberty to approach the respondents for rectification of an error in calculation of interest.
3. JUDICIAL DECISION
The Court dismissed the writ as withdrawn with the liberty sought.
4. OUTCOME
No costs were awarded and pending miscellaneous applications were closed. The Court did not order a refund, quantify an interest entitlement or decide that the adjustments were unlawful.
5. Expert Comments
AKHB editorial analysis, distinct from the Court’s findings.
The final request is narrower than the original prayer
The petition sought relief concerning large refunds and adjustments, but the recorded withdrawal request concerned an interest-calculation error. The operative liberty follows that narrower request; it cannot be presented as a direction granting the original refund relief.
Source: PDF pp.3–4, prayer and paragraphs 3–4
Separate each refund year from the demand years
The source pairs the AY 2021-22 refund with AYs 2014-15 and 2017-18, and the AY 2020-21 amount with AYs 2014-15 and 2018-19. Preserving those pairings helps identify the calculation to be taken to the respondents without suggesting that the Court verified either demand or adjustment.
Source: PDF pp.1–3, prayer
Liberty to approach is not an adjudicated rectification remedy
The Court names no statutory rectification provision, computation method or deadline and does not find the alleged error proved. A representation would need its supporting calculation and records; this order establishes permission to approach the respondents, not a predetermined allowance of that request.
Source: PDF p.4, paragraphs 3–4
Source and verification
Complete 5-page original reviewed; source bytes verified.
Original PDF: 5 pages · SHA-256: ae46531d38b039e6b0ec44d861960a5d21b5fd48696f0114fffba7e9ef2ac230
Full original and all five panels re-reviewed on 21 October 2026.
Current law and subsequent treatment not independently verified.
Subsequent proceedings and current judicial treatment have not been independently verified.
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