JYOTI CARIAPPA SAIKIA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

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W.P.(C)/15086/2023HC DelhiDLHC01046874202321 February 2025Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA2 pages
AI SummaryWithdrawn

What did the High Court hold?

The Delhi High Court held that the writ petitions had become infructuous. The reasoning provided was that the assessment proceedings under Section 153C of the Income Tax Act, 1961, had been completed, and the returned income had been duly accepted. Consequently, the Court found no further purpose for the writ petitions to continue. The ratio decidendi is that once the underlying assessment proceedings, which form the basis of a writ challenge, are concluded and the returned income is accepted, the writ petition becomes infructuous. The operative direction was to dispose of the writ petitions as such, meaning they were closed without a decision on the merits of any specific grievance, due to the changed circumstances.

What were the facts?

The petitioner, Jyoti Cariappa Saikia, filed five writ petitions (W.P.(C) 15086/2023, 15102/2023, 15103/2023, 15104/2023, and 15105/2023) before the Delhi High Court. The respondents were the Deputy Commissioner of Income Tax, Central Circle 5, Delhi, and another. The petitions challenged actions or orders related to assessment proceedings under Section 153C of the Income Tax Act, 1961. The procedural history indicates that the assessment proceedings under Section 153C have been completed. The amount in dispute is not explicitly stated in the provided text.

What were the issues?

1. Whether the writ petitions have become infructuous following the completion of assessment proceedings under Section 153C of the Income Tax Act, 1961? Assessee's Contention: The learned counsel for the writ petitioner submitted that pursuant to the completion of assessment proceedings under Section 153C of the Income Tax Act, 1961, the returned income has been duly accepted, rendering the writ petitions infructuous. Revenue's Contention: The judgment does not record any specific contention from the revenue regarding the petitions being infructuous. However, their presence as respondents indicates their involvement in the proceedings.

Which sections of the Income-tax Act were involved?

Section 153C

AI-generated summary — verify with the full judgment below

Heard together (4 matters)

W.P.(C) 15086/2023
W.P.(C) 15102/2023
W.P.(C) 15103/2023
W.P.(C) 15104/2023

Read from the judgment's own cause title. This page is filed under one of them.

$~46 to 50 * IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(C) 15086/2023 & CM APPL. 60281/2023 (Stay)

JYOTI CARIAPPA SAIKIA

.....Petitioner Through: Mr. Ajay Wadhwa, Ms. Ragini Handa and Mr. Ujjwal Jain, Advs.

versus

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

.....Respondents Through: Mr. Vipul Agrawal, SSC and Mr. Gaoraang Ranjan, Adv. 47 + W.P.(C) 15102/2023 & CM APPL. 60351/2023 (Stay)

JYOTI CARIAPPA SAIKIA

.....Petitioner Through: Mr. Ajay Wadhwa, Ms. Ragini Handa and Mr. Ujjwal Jain, Advs.

versus

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

.....Respondents Through: Mr. Vipul Agrawal, SSC and Mr. Gaoraang Ranjan, Adv. 48 + W.P.(C) 15103/2023 & CM APPL. 60353/2023 (Stay)

JYOTI CARIAPPA SAIKIA

.....Petitioner Through: Mr. Ajay Wadhwa, Ms. Ragini Handa and Mr. Ujjwal Jain, Advs.

versus

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

.....Respondents Through: Mr. Vipul Agrawal, SSC and Mr. Gaoraang Ranjan, Adv. 49 + W.P.(C) 15104/2023 & CM APPL.60355/2023 (Stay)

JYOTI CARIAPPA SAIKIA

.....Petitioner 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 02/07/2025 at 00:10:46

Through: Mr. Ajay Wadhwa, Ms. Ragini Handa and Mr. Ujjwal Jain, Advs.

versus

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

....Respondents Through: Mr. Vipul Agrawal, SSC and Mr. Gaoraang Ranjan, Adv. 50 + W.P.(C) 15105/2023 & CM APPL.60357/2023 (Stay)

JYOTI CARIAPPA SAIKIA

.....Petitioner Through: Mr. Ajay Wadhwa, Ms. Ragini Handa and Mr. Ujjwal Jain, Advs.

versus DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5, DELHI & ANR.

.....Respondents Through: Mr. Vipul Agrawal, SSC and Mr. Gaoraang Ranjan, Adv. CORAM:

HON'BLE MR. JUSTICE YASHWANT VARMA

HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

O R D E R %

21.02.2025

Learned counsel for writ petitioner submits that pursuant to the completion of assessment proceedings under Section 153C of the Income Tax Act 1961, the returned income has been duly accepted and thus, the writ petitions have been rendered infructuous. Consequently, they shall stand disposed of as such.

YASHWANT VARMA, J.

HARISH VAIDYANATHAN SHANKAR, J. FEBRUARY 21, 2025/nd 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 02/07/2025 at 00:10:46

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