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2026 Supreme(Online)(Mad) 48364

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Senthilkumar Ramamoorthy, J
Dassault Systems Simulia Corporation – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent
WP Nos. 12303, 12306, 12307 and 12309 of 2024

Advocates:
For the Appellants/Petitioners: SP Chidambaram
For the Respondents: B. Ramana Kumar, Avinash Krishnan

A petitioner may seek withdrawal of a writ petition where the underlying tax grievance, specifically the non-grant of interest under the Income Tax Act, has been addressed by the respondent authority through subsequent rectification orders.

Headnote:The petitioner challenged the respondent's failure to grant interest under Section 244A of the Income Tax Act, 1961, on tax refunds and sought a writ of mandamus to modify the orders giving effect to higher court directives. The parties submitted that subsequent to the filing, the tax authorities issued rectification orders addressing the interest claims. The central issue was whether the respondent failed to comply with statutory mandates regarding interest payments on refunds. The court did not reach a substantive decision on the merits as the petitioner requested a withdrawal of the proceedings based on the compliance achieved through the rectification orders. The writ petitions are dismissed as withdrawn.

Table of Content
1. dismissal of writ petitions upon grant of relief via rectification. (Para 1 , 2)

W.P. No.12303 of 2024: Petition filed under Article 226 of The Constitution of India praying for the issuance of a writ of mandamus directing the Respondent to appropriately modify its order giving effect to the order of the Honourable High Court in ITBA-GEA-M-260A-2023-24- 1059749159(1) dated 16 January 2024 assessment year 2003-04 with a specific direction to grant interest under Section 244A of the Act from the date of payment of taxes till the date of actual issuance of such refund within such reasonable time as this Honourable Court may think appropriate.

W.P. No.12306 of 2024: Petition filed under Article 226 of The Constitution of India praying for the issuance of a writ of mandamus directing the Respondent to appropriately modify its order giving effect to

the order of the Honourable High Court in ITBA-GEA-M-260A-2023-24- 1059748915(1) dated 16 January 2024 assessment year 2004-05 with a specific direction to grant interest under Section 244A of the Act from the date of payment of taxes till the date of actual issuance of such refund within such reasonable time as this Honourable Court may think appropriate.

W.P. No.12307 of 2024: Petition filed under Article 226 of The Constitution of India praying for the issuance of a writ of mandamus directing the Respondent to appropriately modify its order giving effect to the order of the Honourable High Court in ITBA-GEA-M-260A-2023-24- 1059864363(1) dated 16 January 2024 assessment year 2005-06 with a specific direction to grant interest under Section 244A of the Act from the date of payment of taxes till the date of actual issuance of such refund within such reasonable time as this Honourable Court may think appropriate.

W.P. No.12309 of 2024: Petition filed under Article 226 of The Constitution of India praying for the issuance of a writ of mandamus directing the Respondent to appropriately modify its order giving effect to the order of the Honourable High Court in ITBA-GEA-M-260A-2023-24- 1059749159(1) dated 16 January 2024 assessment year 2006-07 with a specific direction to grant interest under Section 244A of the Act from the date of payment of taxes till the date of actual issuance of such refund within such reasonable time as this Honourable Court may think appropriate.

For Petitioner: Mr.SP Chidambaram in all WPs

For Respondent: Mr. B.Ramana Kumar, Senior Panel Counsel Mr.Avinash Krishnan, Junior Panel Counsel in all WPs

COMMON ORDER

Learned counsel for the petitioner has requested that the writ petitions be dismissed as withdrawn in view of the subsequent development, whereby rectification order dated 03.03.2025 was issued, granting a substantial portion of the interest.

2. Taking note of the request for withdrawal, these writ petitions are dismissed as withdrawn without any order as to costs.

09.06.2026

Index: Yes/No

Neutral Citation: Yes/No mmi

The Deputy Commissioner of Income Tax, International Taxation Circle-1(1), Room No. 407, 4th Floor, Tower 1,

BSNL Building, No. 16, Greams Road, Chennai -600 006.

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2026 Supreme(Online)(Mad) 48364

IN THE HIGH COURT OF JUDICATURE AT MADRASSenthilkumar Ramamoorthy, JDassault Systems Simulia Corporation – AppellantVersusDeputy Commissioner of Income Tax – RespondentWP Nos. 12303, 12306, 12307 and 12309 of 2024

A petitioner may seek withdrawal of a writ petition where the underlying tax grievance, specifically the non-grant of interest under the Income Tax Act, has been addressed by the respondent authority through subsequent rectification orders.

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Senthilkumar Ramamoorthy, J
Dassault Systems Simulia Corporation – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent
WP Nos. 12303, 12306, 12307 and 12309 of 2024