Matrix Green Power Private Limited vs. The Pr. Chief Commissioner of Income Tax

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WP/24859/2025HC TelanganaHBHC01049559202522 August 2025Bench: APARESH KUMAR SINGH,G.M. MOHIUDDIN6 pages
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What did the High Court hold?

The High Court, considering the limited grievance raised by the petitioner and the fact that the appeal under Section 246A of the Income Tax Act, 1961, had been pending for over four years, directed the Appellate Authority/National Faceless Appeal Centre to dispose of the said appeal within a period of four months from the date of receipt of a certified copy of the order by respondent No. 4. The Court explicitly stated that no comments were made on the merits of the case. The writ petition was disposed of accordingly, with no order as to costs. Any pending miscellaneous applications were also closed.

What were the facts?

The petitioner, Matrix Green Power Private Limited, filed a writ petition before the High Court for the State of Telangana at Hyderabad. The petition challenged the inaction of the respondents, including the National Faceless Appellate Centre, in deciding the petitioner's appeal for Assessment Year 2018-19. The appeal was filed on May 20, 2021, under Section 246A of the Income Tax Act, 1961, against an assessment order dated April 22, 2021. The petitioner contended that the appeal had been pending for over four years, which is contrary to the prescribed time limit under Section 250(6A) of the Act. The petitioner sought a direction for expeditious disposal of the appeal.

What were the issues?

1. Whether the inaction of the respondents in deciding the petitioner's appeal for AY 2018-19 for over four years is arbitrary, illegal, and contrary to law, violating the petitioner's fundamental rights under Article 14 of the Constitution of India? (Question of law and fact, concerning the procedural fairness and statutory timelines). Contentions: Assessee (Petitioner): The appeal has been pending for more than four years, which is in violation of Section 250(6A) of the Income Tax Act, 1961, mandating disposal within one year. This prolonged delay is arbitrary and illegal. Revenue (Respondents): The learned Senior Standing Counsel for the Income Tax Department submitted that an appropriate direction may be issued to the Appellate Authority to dispose of the appeal within a reasonable timeframe.

Which sections of the Income-tax Act were involved?

Section 246A,Section 250(6A)

AI-generated summary — verify with the full judgment below

,[3488] HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) FRIDAY, THE TWENTY SECOND DAY OF AUGUST TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE THE CHIEF JUSTICE APARESH KUMAR SINGH AND THE HONOURABLE SRI JUSTICE G.M. MOHIUDDIN WRIT PETITION NO: 24859 OF 2025 Between: Matrix Green Power Private Limited, 8-2-277112, MCH No. 296 UBI Colony, Road No. 3, Banjara Hills, Hyderabad- 500034 Represented by its Director, Sri Kasu Abhiram Reddy ...PETITIONER AND 1 The Pr. Chief Commissioner of lncome Tax, National Faceless Appellate Centre, New Delhi 2. The Commissioner of lncome Tax, (Appeals), National Faceless Appellate Centre, New Delhi 3. The Pr. Commissioner of lncome Tax-4, lT Towers, Masab Tank, Hyderabad 4. The lncome Tax Officer, Ward 16(3) lT Towers, lVlasab Tank, Hyderabad ...RESPONDENTS Petition under Article 226 ot the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate Writ, Order or Direction, more particularly one in the nature of mandamus declaring inaction of the Respondents in not deciding and disposing off the appeal of the Petitioner for AY 2018-19 filed on 20.05.2021 under Section 246A tor more than 4 years as being arbitrary, illegal, contrary to law and encroaching upon the fundamental rights of the Petitioner under Article 14 of the Constitution of lndia and other legal rights and to consequently direct the 2nd Respondent to expeditiously hear and dispose the appeal within a period of4to6weeks.

*7 I ./: lA NO: 1 OF 2025 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to direct the Respondents to consider the request of the petitioner dated 23.06.2025 for an early hearing of the appeal. Counsel for the Petitioner : Ms.K.MAMATA Counsel for the Respondents: Ms.B.SAPNA REDDY, Sr.SC for lT DEPT The Court made the following: ORDER

-,K: I THE HON'BLE THE CHIEF JUSTICE SRI APARESH KI'MAR SINGH AND THE HON'BLE SRI JUSTICE G.M.MOHIIIDDIN IITRIT PETITION No.24859 of 2o25 ORDER: Learned counsel Ms. K.Mamata Choudary appears for the petitioner Ms. B.Sapna Reddy, learned Senior Standing Counsel for Income Tax Department, appears for the respondents. 2. The simple prayer of the petitioner is to issue a direction to the Appeilate Authority/ National Faceless Appeal Centre to decide the appeal preferred by the petitioner under Section 246A of the Income Tax Act, 1961 (hereinafter referred to as, "the Act"), instituted on 20.O5.2021 against the assessment order dated 22.O4.2021 passed by the faceless authority. 3. Learned counsel for the petitioner submits that now for more than four years, the appeal preferred by the petitioner has not been decided, though there is a prescription under Section 250(6A) of the Act to decide the , t l

J- I I 2 appeal within one year, Therefore, the pctitioner has beei-t compelled to approach this Court. 4. Learned Senior Standing Counsel for Income 'lax Department appearing for the respondents submits that appropriate direction may be issued to the Appellate Authority to dispose of the appeal preferred by the petrtioner within a reasonable t.imeframe 5. Having regard to the limitcd grievance raised by the petitioner and in view of thc fact that the appeal preferred by the petitioner under Section 246A of the Act is pending for more than four years, the ,{ppellate Authority/ National Faceless Appeal Centre shall disposc of the said appeal within a period of four months from the date of receipt of a certified copy of the order by respondent No.4. Let it be made clear that we have not made any comments on the merits of the case. 6. The writ petition is disposed of accordingly. However, { there shall be no order as to costs I

J Miscellaneous applications pending, if any, shall stand closed //TRUE COPYII SD/.L.LAKSHMI BABU DEPUW REGISTRAR SECTION OFFICER To, 7. BSK LS 1. The Pr. Chief Commissioner of lncome Tax, National Faceless Appellate Centre, New Delhi 2. The Commissioner of lncome Tax, (Appeals), National Faceless Appellate Centre, New Dethi 3- The Pr. Commissioner of lncome Tax-4, lT Towers, fVlasab Tank, Hyderabad 4. The lncome Tax Officer, Ward 16(3) lT Towers, Masab Tank, Hyderabad 5. One CC to tMs.K.lt/AMATA, Advocate, [OPUC] 6. One CC to Ms.B.SAPNA REDDY, SC for lncome Tax Department. IOPUCI Two CD Copies. 8p- I l:

HIGH COURT DN|ED',2210812025 ORDER WP.No.24859 of 2025 DISPOSING OF THE WRIT PETITION WITHOUT COSTS $ "f 4 r--'( o (l 23llJE i -ar- /.... a [i] f 2s

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