M/S JINDAL CHARITABLE SOCIETY vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 29 & ANR.

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W.P.(C)/13612/2025HC DelhiDLHC01064574202504 September 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryWithdrawn

What did the High Court hold?

The Delhi High Court disposed of the writ petition as infructuous. The Court noted that the revenue had submitted a communication dated September 1, 2025, which stated that the attachment of the petitioner's bank account, pursuant to the notice dated August 20, 2025, under Section 226(3) of the Income Tax Act, 1961, had been revoked with immediate effect. The petitioner's counsel confirmed that nothing further survived in the writ petition in light of this revocation. Therefore, the Court did not delve into the merits of the legality or jurisdiction of the original attachment order. The operative direction was to dispose of the petition as infructuous.

What were the facts?

The petitioner, M/s Jindal Charitable Society, filed a writ petition before the Delhi High Court challenging a letter dated August 20, 2025, issued under Section 226(3) of the Income Tax Act, 1961. This letter had resulted in the attachment of the petitioner's bank account. The revenue, represented by the Assistant Commissioner of Income Tax, Central Circle 29, Delhi, submitted a communication dated September 1, 2025, to the Court. This communication stated that the attachment of the aforementioned bank account was revoked with immediate effect, and normal operation of the account should be allowed. The petitioner's counsel acknowledged that nothing further survived in the writ petition.

What were the issues?

1. Whether the letter dated August 20, 2025, issued under Section 226(3) of the Income Tax Act, 1961, for attachment of the petitioner's bank account, is patently illegal, contrary to law, passed without jurisdiction, and in violation of relevant provisions of law? (Question of law and fact, concerning Section 226(3) of the Income Tax Act, 1961). Assessee's Contention: The petitioner argued that the impugned letter was illegal, without jurisdiction, and violative of law. (No specific authorities or precedents were named in the provided text). Revenue's Contention: The revenue submitted a communication indicating that the attachment of the bank account had been revoked with immediate effect. (No specific authorities or precedents were named in the provided text).

Which sections of the Income-tax Act were involved?

Section 226(3)

AI-generated summary — verify with the full judgment below

$~61 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 13612/2025, CM APPL. 55818/2025 CM APPL. 55819/2025 CM APPL. 55820/2025 M/S JINDAL CHARITABLE SOCIETY

.....Petitioner Through: Ms. Kavita Jha, Sr. Adv. with Mr. N.P. Saini, Mr. Abhinav Jain and Mr. Himanshu Aggarwal, Advs. versus ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 29 & ANR.

.....Respondents Through: Mr. Gaurav Gupta, SSC with Mr. Shivendra Singh and Mr. Yojit Pareek, JSCs and Mr. Surya Jindal, Adv. for Income Tax Department Ms. Rashmi, Adv. for R2/Indusind Bank CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

04.09.2025 1. This petition has been filed with the following prayer:- “Quash and set aside the impugned letter dated 20.08.2025 issued under Section 226(3) of the Act, for being patently illegal, contrary to the applicable law, passed/issued without jurisdiction, in violation of the relevant provisions of law governing such acts thereunder, and other grounds taken vide present Petition;” 2. Mr. Gaurav Gupta, learned Senior Standing Counsel for the respondent/revenue has placed before us a communication dated 01.09.2025, This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 09/09/2025 at 12:25:40

received from the Assistant Commissioner of Income Tax, Central Circle, 29, Delhi, which reads as under:- “.......Please refer to the notice u/s 226 (3) of the Income Tax Act, 1961 having DIN & Notice no. ITBA/COM/F/17/2025- 26/1079771338(1) dated 20.08.2025 vide which bank account no. 159599112755. 159958687029 held in your bank was attached. Now, the attachment of aforementioned bank account of the assessee may be revoked with immediate effect and the normal operation of the bank account be allowed......... “ 3. According to Mr. Gaurav Gupta, the communication makes it clear that the attachment of the bank account, for which the petitioner has approached this court, has been revoked with immediate effect. On this, Ms. Kavita Jha, learned senior advocate for the petitioner says nothing further survives in the writ petition and the same be disposed of as infructuous. 4. Accordingly, the petition is disposed of as infructous. V. KAMESWAR RAO, J VINOD KUMAR, J SEPTEMBER 4, 2025 cd This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 09/09/2025 at 12:25:40

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