M.P. State Civil Supplies Corporation Limited vs. Assistant Commissioner Of Incom Tax Dcit/ Acit Bhopal
What did the High Court hold?
The High Court held that the writ petition was rendered infructuous. The Court noted that the petitioner had filed appeals before the Commissioner of Income Tax (Appeal) against the reassessment orders, and these appeals had been dismissed on merit. Given this procedural history, the Court found that the petitioner's available remedy was to approach the Income Tax Appellate Tribunal. Therefore, the writ petition was dismissed as infructuous. No decision was made on the merits of the reassessment orders themselves.
What were the facts?
The petitioner, M.P. State Civil Supplies Corporation Limited, filed a writ petition challenging two reassessment orders for assessment year 2016-2017 and consequential demand orders dated March 26, 2022, and March 30, 2025. The petitioner had previously filed appeals before the Commissioner of Income Tax (Appeal), Bhopal, against these reassessment orders. The respondents submitted an application stating that both appeals filed by the petitioner have already been dismissed on merit. Consequently, the writ petition was rendered infructuous as the petitioner's appeals were dismissed, and the available remedy was to approach the Income Tax Appellate Tribunal.
What were the issues?
1. Whether the writ petition is maintainable when the petitioner has already filed appeals before the Commissioner of Income Tax (Appeal) and those appeals have been dismissed on merit, rendering the writ petition infructuous? (Question of law) Assessee's Contention: The petitioner filed a writ petition challenging reassessment orders. (No specific argument recorded regarding the maintainability of the writ petition in light of dismissed appeals). Revenue's Contention: The respondents argued that the petitioner's appeals against the reassessment orders were dismissed on merit by the Commissioner of Income Tax (Appeal). Therefore, the writ petition challenging the same reassessment orders has become infructuous. The respondents pointed out that the petitioner's remedy lies in approaching the Income Tax Appellate Tribunal.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE VIVEK RUSIA & HON'BLE SHRI JUSTICE PRADEEP MITTAL ON THE 17th OF NOVEMBER, 2025 WRIT PETITION No. 30975 of 2025 M.P. STATE CIVIL SUPPLIES CORPORATION LIMITED Versus ASSISTANT COMMISSIONER OF INCOM TAX DCIT/ ACIT BHOPAL AND OTHERS Appearance: Shri Ajay Chhazed - Advocate for the petitioner (through video conferencing mode). Shri Harpreet Singh Gupta - Advocate for the respondents No.1, 3 and 4. ORDER Per: Justice Vivek Rusia The petitioner has filed this petition challenging two reassessment orders passed under Section 143(3) r/w Section 263 of the Income-tax Act for the assessment year 2016-2017 and consequential demand orders dated 26.03.2022 and 30.03.2025. 2. The petitioner has declared in para-2 that against the aforesaid reassessment order, an appeal before the Commissioner of Income Tax (appeal), Bhopal, has already been filed. 3. Learned counsel for the respondents No.1, 3 and 4 has filed an 1 WP-30975-2025 NEUTRAL CITATION NO. 2025:MPHC-JBP:58736 Signed by: SHRUTI JHA Signing time: 24-11- 2025 11:30:35 Signature Not Verified
(VIVEK RUSIA) JUDGE (PRADEEP MITTAL) JUDGE application for placing documents on record that both the Appeals No.NFAC/2015-16/10125993 and NFAC/2015-16/10489075 filed by the petitioner have already been dismissed on merit. Therefore, this present writ petition has been rendered infructuous. Since, the petitioner is challenging the order of reassessment, against which two appeals were preferred and both have been dismissed. Now, the petitioner has a remedy to approach the Income Tax Appellate Tribunal. 4. Accordingly, the petition is dismissed as infructuous. Shruti
2 WP-30975-2025 NEUTRAL CITATION NO. 2025:MPHC-JBP:58736 Signed by: SHRUTI JHA Signing time: 24-11- 2025 11:30:35 Signature Not Verified
More judgments on Section 263
- Gillette India Limited, Mumbai vs Principal Commissioner of Income Tax, JaipurITA 1316/JPR/2026[2018-19]Status: Disposed16 Oct 2026AY 2018-19
- Neo Structo Construction P. Ltd., Ahmedabad vs The Pr. CIT- 3, AhmedabadITA 1216/AHD/2026[2015-2016]Status: Disposed16 Oct 2026AY 2015-2016
- Vimal Harilal Baldania, Gandhidham vs The ITO Ward 2, GandhidhamITA 770/RJT/2025[2017-18]Status: Disposed15 Oct 2026AY 2017-18
- J.D. Marketing, Kolkata vs ITO, Ward 37(1), KolkataITA 1493/KOL/2026[2015-2016]Status: Disposed15 Oct 2026AY 2015-2016
- J.D. Marketing, Kolkata vs ITO, Ward 37(1), KolkataITA 1492/KOL/2026[2013-2014]Status: Disposed15 Oct 2026AY 2013-2014
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