RAVI SURYA DEVELOPERS PRIVATE LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX

CW/10814/2021HC RajasthanRJHC02062558202124 September 2025Author: MAHENDAR KUMAR GOYAL,SANJEET PUROHIT2 pages

AI SummaryRemanded

What did the High Court hold?

The High Court, in its order dated 24/09/2025, disposed of the instant writ petitions in terms of a previous order passed by a coordinate Bench of the same High Court on 26.03.2025 in the case of Friends SPS International India (P) Ltd. & Ors. versus Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors. (D.B. Civil Writ Petition No.3372/2021 and other connected matters). The Court noted that the issue involved in the present petitions was no longer res integra and had been resolved by the aforementioned coordinate Bench decision. Consequently, the petitions were ordered to be disposed of accordingly. The specific findings or reasoning of the coordinate Bench, which formed the basis for this disposal, are not elaborated in this order. Any pending applications were also disposed of.

What were the facts?

These are two connected writ petitions filed by different sets of petitioners challenging orders passed by the Income Tax Settlement Commission (ITSC). In the first petition (D.B. Civil Writ Petition No. 2915/2021), the petitioner is Gopal Goyal, and the respondents include the Deputy Commissioner of Income Tax and the ITSC. In the second petition (D.B. Civil Writ Petition No. 10814/2021), the petitioners are Ravi Surya Developers Private Limited and other related entities, along with Ravindra Pratap Singh Parihar, and the respondents include the Assistant Commissioner of Income Tax and the ITSC. The specific assessment years and the amounts in dispute are not detailed in this order. The procedural history involves the petitioners approaching the ITSC, and subsequently filing these writ petitions challenging the ITSC's decisions.

What were the issues?

1. Whether the Income Tax Settlement Commission (ITSC) erred in its decision regarding the settlement applications filed by the petitioners, and if so, what is the appropriate relief? (Question of law and mixed fact and law, concerning the powers and jurisdiction of the ITSC under the Income Tax Act, 1961). Assessee's Contention: The learned counsel for the petitioners submitted that the issue involved in these writ petitions is no longer res integra and has been resolved by a coordinate Bench of this Court in the case of Friends SPS International India (P) Ltd. & Ors. versus Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors. They prayed for disposal of the instant matters in terms of that order. Revenue's Contention: The judgment does not record any specific arguments made by the revenue's counsel. However, the presence of revenue counsel indicates their participation in the proceedings.

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

[2025:RJ-JP:39395-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 2915/2021 Gopal Goyal S/o Shri Kedar Lal Goyal, R/o B-10, Gopal Krishna Nikunj, Tulsidasji Ki Bagichi, Janta Colony, Jaipur. ----Petitioner Versus 1. Deputy Commissioner Of Income Tax, Central Circle I, NCR Building, Statue Circle, Jaipur. 2. Income Tax Settlement Commission, 4Th Floor, Lok Nayak Bhavan, New Delhi 110003 3. Union Of India, Through Secretary, Ministry Of Finance, 3Rd Floor, Jeevan Deep Building, Sansad Marg, New Delhi 110001 ----Respondents Connected With D.B. Civil Writ Petition No. 10814/2021 1. Ravi Surya Developers Private Limited, K-47-48, Himmat Nagar, Tonk Road, Jaipur Through Authorised Signatory Ravindra Pratap Singh Parihar 2. Ravi Surya Builders Private Limited, K-48, Himmat Nagar, Tonk Road, Jaipur Through Authorised Signatory Ravindra Pratap Singh Parihar 3. Greater Sitapura Developers Private Limited, F-139, Sitapura Industrial Area, Tonk Road, Jaipur Through Authorised Signatory Ravindra Pratap Singh Parihar 4. Ravindra Pratap Singh Parihar, S/o Shri Bhagwan Singh Parihar, Aged About 47 Years, R/o P-28, Raj Aangan, Nri Colony, Pratap Nagar, Sanganer, Jaipur 5. Ravi Surya Affordable Homes Private Limited, E-172 A, Uttam Tower, Ramesh Marg, C-Scheme, Jaipur Through Authorised Signatory Ravindra Pratap Singh Parihar ----Petitioners Versus 1. Assistant Commissioner Of Income Tax, Central Circle 3 Jaipur, New Central Revenue Building, Statue Circle, Jaipur 2. 2. Income Tax Settlement Commission, 4Th Floor, Lok Nayak Bhavan, New Delhi 110003 Through Registrar. 3. Union Of India, Through Finance Secretary, Ministry Of Finance (Department Of Revenue), Central Board Of Direct Taxes, North Block, New Delhi 110002 ----Respondents For Petitioner(s) : Mr. Gunjan Pathak For Respondent(s) : Mr. Devesh Yadav Mr. Rajat Sharma Mr. Ashish Kumar Mr. Digvijay Singh for [2025:RJ-JP:39395-DB] (2 of 2) [CW-2915/2021] Mr. R. D.Rastogi, ASG Mr. Siddharth Bapna Mr. Meyhul Mittal Mr. Rahul Kumar Mr. Tanushka Saxena Ms. Chinki choudhary HON'BLE MR. JUSTICE MAHENDAR KUMAR GOYAL HON'BLE MR. JUSTICE SANJEET PUROHIT

Order 24/09/2025 Learned counsel appearing for respective parties submit that the issue involved herein is no more res integra and stands resolved by a coordinate Bench of this Court vide order dated 26.03.2025 passed in the case of Friends SPS international India (P) Ltd. & Ors. versus Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors.: D.B. Civil Writ Petition No.3372/2021 and other connected matters, and prays for disposal of the instant matters in terms thereof.

Ordered accordingly.

Pending application(s), if any, also sands disposed of. (SANJEET PUROHIT),J (MAHENDAR KUMAR GOYAL),J TN/94-95

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