PCI LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1) DELHI & ANR.

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W.P.(C)/3804/2024HC DelhiDLHC01013089202405 July 2024Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA3 pages
AI SummaryWithdrawn

What did the High Court hold?

The Delhi High Court held that the writ petitions filed by PCI Limited had been rendered infructuous. This decision was based on the information provided by the Revenue that the assessment proceedings undertaken under Section 153C of the Income Tax Act, 1961, had been terminated with no additions having been made to the assessee's income. Consequently, the Court found no necessity to adjudicate on the merits of the petitions. The reasoning was that once the underlying assessment proceedings, which were the subject of challenge, were brought to a close without any adverse findings or additions, the petitions seeking to challenge those proceedings became moot. The operative direction was to dispose of the writ petitions as infructuous. No specific issue was left undecided, as the petitions were disposed of on a procedural ground.

What were the facts?

The petitioner, PCI Limited, filed multiple writ petitions (W.P.(C) 3834/2024, 3804/2024, 3808/2024, 3809/2024, 3811/2024, and 3812/2024) before the Delhi High Court. The respondents were the Assistant Commissioner of Income Tax Circle 19(1), Delhi, and another. The petitions challenged assessment proceedings initiated under Section 153C of the Income Tax Act, 1961. The proceedings were undertaken by the revenue against the assessee. The specific assessment years and the amounts in dispute were not recorded in the judgment. The procedural history indicates that the writ petitions were filed challenging these assessment proceedings.

What were the issues?

1. Whether the writ petitions challenging the assessment proceedings under Section 153C of the Income Tax Act, 1961, are maintainable in light of the termination of those proceedings? The Assessee (Petitioner) argued that the writ petitions were filed to challenge the assessment proceedings initiated under Section 153C. The Revenue (Respondents) informed the Court that the assessment proceedings had been terminated with no additions made. The Revenue did not explicitly state their arguments regarding the maintainability of the writ petitions, but their submission regarding the termination of proceedings formed the basis for the Court's decision.

Which sections of the Income-tax Act were involved?

Section 153C

AI-generated summary — verify with the full judgment below

Heard together (3 matters)

W.P.(C) 3834/2024
W.P.(C) 3804/2024
W.P.(C) 3808/2024

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

$~32, 43, 45 to 48 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 3834/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1) DELHI & ANR.

.....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. 43 + W.P.(C) 3804/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1) DELHI & ANR.

.....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. 45 + W.P.(C) 3808/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1) DELHI & ANR.

.....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. 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 03/07/2025 at 08:16:43

46 + W.P.(C) 3809/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1) DELHI & ANR.

.....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. 47 + W.P.(C) 3811/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1), DELHI & ANR. .....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. 48 + W.P.(C) 3812/2024 PCI LIMITED

.....Petitioner Through: Mr. Sumit Lalchandani, for Mr. Salil Kapoor, Advocate. versus ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(1), DELHI & ANR. .....Respondents Through: Mr. Aseem Chawla, SSC with Ms. Naincy Jain, JSC, Ms. Pratishtha Chaudhary & Mr. Naveen Rohila, Advocates. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE RAVINDER DUDEJA 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 03/07/2025 at 08:16:43

O R D E R %

05.07.2024 1. We have been informed that pursuant to termination of the assessment proceedings which were undertaken under Section 153C of the Income Tax Act, 1961, the proceedings have been brought to a close with no additions having been made. 2. In view of the aforesaid, the instant writ petitions are rendered infructuous. They are accordingly disposed of. YASHWANT VARMA, J. RAVINDER DUDEJA, J. JULY 5, 2024/RM/SK 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 03/07/2025 at 08:16:43

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