SAJJAN SINGH VERMA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-19, DELHI & ANR.
What did the High Court hold?
The Delhi High Court, comprising the Chief Justice and Mr. Justice Tushar Rao Gedela, held that the writ petitions had become infructuous. This conclusion was based on the submission made by the learned senior counsel for the petitioner that the final assessment order had been passed during the pendency of the writ petitions. Consequently, the Court found no further purpose in continuing with the writ proceedings. The ratio decidendi is that if the subject matter of a writ petition is resolved by a subsequent event, such as the passing of a final order that supersedes the challenged action, the petition becomes infructuous and should be dismissed. The operative direction was to dismiss the petitions as infructuous.
What were the facts?
These are four writ petitions filed by Sajjan Singh Verma challenging certain actions or orders of the Deputy Commissioner of Income Tax, Central Circle-19, Delhi. The petitions were filed before the Delhi High Court. During the pendency of these writ petitions, the final assessment order has been passed by the revenue authorities. The petitioner's counsel informed the Court that the petitions have become infructuous due to this subsequent development. The revenue was represented by its Standing Counsel and Junior Standing Counsel.
What were the issues?
1. Whether the writ petitions have become infructuous due to the passing of the final assessment order during their pendency, and consequently, if they should be dismissed as such. The petitioner, through their senior counsel, argued that the passing of the final assessment order has rendered the writ petitions infructuous. The revenue, represented by its counsel, did not appear to contest this submission or present any counter-arguments regarding the maintainability or merits of the petitions.
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$~43,45-47 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 361/2025 & CM APPL. 1761/2025, CM APPL. 1762/2025
SAJJAN SINGH VERMA
.....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Aniket D. Agarwal, Mr. Ruchesh Sinha and Ms. Monalisa Maity, Advs.
versus DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-19, DELHI & ANR.
.....Respondent Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shainwal, JSC for Revenue.
+ W.P.(C) 362/2025 & CM APPL. 1763/2025, CM APPL. 1764/2025
SAJJAN SINGH VERMA
.....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Aniket D. Agarwal, Mr. Ruchesh Sinha and Ms. Monalisa Maity, Advs.
versus DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-19, DELHI & ANR.
.....Respondent Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shainwal, JSC for Revenue.
+ W.P.(C) 363/2025 & CM APPL. 1766/2025, CM APPL. 1767/2025
SAJJAN SINGH VERMA
.....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Aniket D. Agarwal, Mr. Ruchesh Sinha and Ms. Monalisa Maity, Advs.
versus DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-19, DELHI & ANR.
.....Respondent Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shainwal, JSC for Revenue. 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 01/07/2025 at 20:34:10
+ W.P.(C) 364/2025 & CM APPL. 1768/2025, CM APPL. 1769/2025
SAJJAN SINGH VERMA
.....Petitioner Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Aniket D. Agarwal, Mr. Ruchesh Sinha and Ms. Monalisa Maity, Advs.
versus
DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-19, DELHI & ANR.
.....Respondent Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Shainwal, JSC for Revenue.
CORAM: HON'BLE THE CHIEF JUSTICE
HON'BLE MR. JUSTICE TUSHAR RAO GEDELA
O R D E R %
10.03.2025
Learned senior counsel for the petitioner has stated that these petitions have been rendered infructuous for the reason that the final assessment order has been passed during the pendency of the writ petitions. 2. Accordingly, the petitions are dismissed as such.
DEVENDRA KUMAR UPADHYAYA, CJ
TUSHAR RAO GEDELA, J MARCH 10, 2025 N.Khanna 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 01/07/2025 at 20:34:10
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