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

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W.P.(C)/3809/2024HC DelhiDLHC01013094202405 July 2024Bench: HON'BLE MR. JUSTICE RAVINDER DUDEJA,HON'BLE MR. JUSTICE YASHWANT VARMA3 pages
AI SummaryWithdrawn

What did the High Court hold?

The Delhi High Court held that the writ petitions filed by PCI Limited were rendered infructuous. This decision was based on the information provided to the Court that the assessment proceedings undertaken under Section 153C of the Income Tax Act, 1961, had been terminated and brought to a close with no additions having been made to the assessee's income. Consequently, the Court disposed of the writ petitions as infructuous, meaning they no longer required adjudication on their merits as the underlying issue had been resolved. No specific legal principle or ratio decidendi for future citation was explicitly stated, beyond the procedural outcome of disposing of cases that have become moot.

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 petitions were filed against the Assistant Commissioner of Income Tax, Circle 19(1), Delhi, and another respondent. The assessment proceedings under challenge were undertaken under Section 153C of the Income Tax Act, 1961. The High Court was informed that these assessment proceedings have been terminated and brought to a close without any additions being made to the assessee's income.

What were the issues?

1. Whether the writ petitions filed by PCI Limited are rendered infructuous in light of the termination of assessment proceedings under Section 153C of the Income Tax Act, 1961, without any additions being made. Assessee's Contention: The assessee, PCI Limited, through its counsel, presented the writ petitions. While specific arguments are not detailed, the filing of the writ petitions implies a challenge to the assessment proceedings or related actions. The subsequent information that the proceedings were terminated without additions suggests that the original grievance, whatever it may have been, has been resolved. Revenue's Contention: The respondents, represented by the Standing Counsel for the Income Tax Department, informed the Court about the termination of the assessment proceedings under Section 153C without any additions. This information 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 08:16:32

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 08:16:32

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 08:16:32

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