The Delhi High Court recently restrained the Income Tax Department from taking coercive steps to recover tax from international law firm Holman Fenwick Willan Singapore LLP pursuant to an assessment order passed against the firm in 2025.

A Division Bench of Justices Dinesh Mehta and Aditi Choudhary passed the order after the law firm submitted that it had no presence in India, yet the Income Tax Department had allotted it a Permanent Account Number (PAN) without any application.

"The respondents shall not take any coercive measure for recovery of the demand raised by assessment order dated 09.05.2025 and consequential demand notice dated 24.12.2025 issued to the petitioner," the Court said.

The Court passed the order on October 16 after the law firm challenged an assessment order dated May 9, 2025, a penalty order dated December 24, 2025, and the consequential demand notice issued on the same date.

Appearing for the firm, advocate Vibhooti Malhotra submitted that Holman Fenwick Willan Singapore LLP was a maritime law firm with no presence in India and had never applied for a PAN.

She alleged that the Income Tax Department had nevertheless allotted a PAN to the firm and proceeded to assess its income without its knowledge.

After hearing the submissions, the Court granted interim relief to the firm and directed Senior Standing Counsel Puneet Rai, appearing for the Income Tax Department, to obtain instructions and file a short counter-affidavit within three weeks.

The matter will be heard next on November 18.

Advocates Bhuvnesh Satija and Aniket Khanduri also represented the law firm.

Besides Rai, Junior Standing Counsel Ashwini Kumar and Rishabh Nangia also appeared for the Income Tax Department.

[Read Order]