PRINCIPAL COMMISSIONER OF INCOME TAX-I vs. M/S RAJASTHAN AGENCIES PVT LTD

ITA/216/2018HC RajasthanRJHC02060540201815 December 2021Bench: AKIL KURESHI,UMA SHANKER VYAS2 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court held that the appeals filed by the Revenue have become infructuous. This is because the assessee had applied for settlement of disputes before the Settlement Commission, and the competent authority under the Settlement Commission had quantified an amount for settlement. The assessee has subsequently paid this quantified amount to the department, as evidenced by the copies of payments produced. Consequently, the appeals are disposed of as infructuous. The court granted liberty to the Revenue to apply afresh if any difficulty arises in the future. No specific issue regarding the merits of the original assessment or the ITAT's order was decided.

What were the facts?

The appeals were filed by the Principal Commissioner of Income Tax-I, Jaipur (Revenue) against M/s Rajasthan Agencies Pvt Ltd (Assessee). The assessment years are not specified. The appeals challenge orders passed by the Income Tax Appellate Tribunal (ITAT). The procedural history indicates that the assessee had applied for settlement of disputes with the Settlement Commission. The Settlement Commission quantified an amount for settlement, which the assessee has paid to the department. The assessee produced copies of these payments.

What were the issues?

1. Whether the appeals filed by the Revenue have become infructuous in light of the assessee's settlement with the Settlement Commission and payment of the quantified amount. Assessee's Contention: The assessee, through its counsel, stated that it had applied for settlement of disputes under the Settlement Commission. The Settlement Commission quantified the settlement amount, which the assessee has paid. Copies of payment were produced. Revenue's Contention: The judgment does not record any specific contention from the Revenue regarding the merits of the appeals. The appeals are rendered infructuous due to the settlement process initiated by the assessee.

AI-generated summary — verify with the full judgment below

HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Income Tax Appeal No. 210/2018 Principal Commissioner Of Income Tax-I, New Central Revenue Building Statue Circle, Jaipur Raj ----Appellant Versus M/s Rajasthan Agencies Pvt Ltd, 507, Navjeevan Complex Station Road, Jaipur Rajasthan ----Respondent Connected With D.B. Income Tax Appeal No. 216/2018 Principal Commissioner Of Income Tax-I, New Central Revenue Building, Statue Circle, Jaipur (Raj) ----Appellant Versus M/s Rajasthan Agencies Pvt Ltd, 507, Navjeevan Complex, Station Road, Jaipur ----Respondent For Appellant(s) : Mr. Anuroop Singhi For Respondent(s) : Mr. Anant Kasliwal HON'BLE THE CHIEF JUSTICE MR. AKIL KURESHI HON'BLE MR. JUSTICE UMA SHANKER VYAS Order 15/12/2021 Learned advocate for the assessee stated on instructions that the assessee had applied for settlement of the disputes. The competent authority under the Settlement Commission has quantified the amount to be paid by the assessee for settlement of disputes which also the assessee has paid. He produces copies of the payments made to the department.

(2 of 2) [ITA-210/2018] In that view of the matter, these appeals filed by the revenue would be rendered infructuous and disposed of accordingly with liberty to apply afresh in case the difficulty arises. All pending applications are also disposed of. (UMA SHANKER VYAS),J (AKIL KURESHI),CJ BRIJ MOHAN GANDHI /28 & 29

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