M/S STATE BANK OF PATIALA vs. THE PRINCIPAL COMMISSIONER OF INCOME, PATIALA
What did the High Court hold?
The High Court held that the appeal filed by the appellant-Bank had become infructuous. This conclusion was based on the submission made by the appellant-Bank's counsel, who stated that an order dated January 10, 2023, passed by the Income Tax Appellate Tribunal rendered the present appeal infructuous. The Court accepted this submission and ordered the appeal to be disposed of accordingly. No specific findings were made on the merits of the original dispute between the assessee and the revenue, as the appeal was decided on a procedural ground. The operative direction was to dispose of the appeal as infructuous.
What were the facts?
The appeal was filed by M/s State Bank of Patiala (the appellant-Bank) against the Principal Commissioner of Income Tax (the respondent). The High Court of Punjab and Haryana at Chandigarh was hearing the appeal. The appellant-Bank, through its learned Senior Counsel, submitted that the present appeal had become infructuous pursuant to an order dated January 10, 2023, passed by the Income Tax Appellate Tribunal (the Tribunal). Consequently, the appellant-Bank requested that the appeal be disposed of as such. The Court acknowledged this submission and ordered accordingly.
What were the issues?
The High Court was not required to decide any substantive issues of law or fact. The sole matter before the Court was the appellant-Bank's submission that the appeal had become infructuous. The appellant-Bank argued that due to an order passed by the Income Tax Appellate Tribunal on January 10, 2023, the appeal filed before the High Court was rendered infructuous and should therefore be disposed of. The respondent (Principal Commissioner of Income Tax) did not appear to have made any arguments on the merits of the case as the appeal was withdrawn based on the subsequent Tribunal order.
AI-generated summary — verify with the full judgment below
IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH ITA-494-2018(O&M) Date of decision: 21.01.2025 M/s State Bank of Patiala … Appellant Versus The Principal Commissioner of Income Tax … Respondent CORAM: HON’BLE MR. JUSTICE ARUN PALLI HON’BLE MRS. JUSTICE SUDEEPTI SHARMA Present: Mr. Sanjay Bansal, Senior Advocate, with Mr. Gurdeep Singh, Advocate, for the appellant-Bank. Mr. Saurabh Kapoor, Senior Standing Counsel, and Ms. Muskaan Gupta, Advocate, for the respondent. *** ARUN PALLI, J. (Oral) CM-21688-CII-2024 Order (Annexure A-7) is taken on record. The application is allowed. ITA-494-2018(O&M) Learned Senior counsel for the appellant-Bank submits, for, pursuant to the order dated January 10, 2023, passed by the Tribunal, the present appeal is rendered infructuous, and the same be disposed of as such. Ordered accordingly. ( Arun Palli )
Judge 21.01.2025 Rajan ( Sudeepti Sharma ) Judge Whether speaking / reasoned: YES/NO Whether Reportable: YES/NO RAJAN KUMAR 2025.01.23 11:01 I am approving this document
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