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The Rajasthan High Court, Bench at Jaipur, disposed of the writ petition by directing the release of the TDS refund forthwith. The Court acknowledged that the issue was covered by the Supreme Court's judgment in Bharti Cellular Limited (Now Bharti Airtel Limited) Vs. Assistant Commissioner of Income Tax, Circle 57, Kolkata and another. The Supreme Court had held that assessees are not obligated to deduct tax at source on the income/profit component in payments received by distributors/franchisees from third parties/customers, or while selling/transferring prepaid coupons or starter kits to distributors, and that Section 194H of the Act is not applicable. The High Court upheld the ITAT's order which was in line with this Supreme Court ruling. The Court left it open for the department to pursue any separate demands against the petitioner and for the petitioner to defend against such demands.
The High Court held that proceedings under Section 148A of the Income Tax Act, 1961, cannot be initiated against a deceased assessee. The Court reiterated the well-settled law that such proceedings require compliance with Section 159 of the Act, which provides for the liability of legal representatives. The Court noted that the department had initiated proceedings under Section 148A against the deceased assessee without taking recourse to Section 159. The Court relied on its previous judgments in D.B. Civil Writ Petition No.9985/2023 and D.B. Civil Writ Petition No.15115/2022, which had settled this proposition. Consequently, the notices issued under Section 274 of the Act were quashed and set aside. The Court granted liberty to the respondents (the department) to reinitiate proceedings against the legal representatives of the deceased assessee strictly in accordance with the provisions of Sections 148A(b) and 159 of the Act.
The High Court dismissed the instant appeal filed by the Revenue. The dismissal was based on the tax effect of Rs. 53,68,441/-, which was found to be below the monetary limit prescribed by the Central Board of Direct Taxes (CBDT) in its Circular dated 17.09.2024. The Court noted that the Circular specified monetary limits for filing appeals before the High Court, and this appeal fell below that threshold. The Court explicitly stated that the proposed substantial question of law is kept open to be adjudicated in appropriate proceedings in the future. Any pending applications were also disposed of.
The High Court noted that the appeal against the assessment order for AY 2018-19 was dismissed by the CIT(A) and is now pending before the ITAT. The appeal for AY 2013-14 is pending before the CIT(A). The Court observed that the ITAT, while hearing an appeal, possesses the inherent power to grant or decline stay, including imposing conditions like pre-deposit. Given that the ITAT has the authority to pass necessary orders, including those related to stay and pre-deposit, the High Court expressed no inclination to interfere. The Court acknowledged that the writ petition was filed in 2023 and had been pending without interim orders, while ITAT proceedings had also not progressed. Therefore, the petition was disposed of with the expectation that the ITAT would take up the matter and pass appropriate orders, including on the stay prayer. The Court also expected the CIT(A) to decide the pending appeal for AY 2013-14 in due course. The stay application was also disposed of.
The High Court dismissed the instant appeal filed by the Revenue. The dismissal was based on the tax effect of Rs.55,33,866/-, which was found to be below the monetary limit prescribed by the Central Board of Direct Taxes (CBDT) in its Circular dated 17.09.2024 for filing appeals before the High Court. The Circular stipulated a monetary limit of Rs.2 crore for appeals before the High Court. The Court noted that the proposed substantial question of law was kept open to be adjudicated in future appropriate proceedings. Any pending applications were also disposed of.
The High Court allowed the miscellaneous application for revival. The court recalled its previous order dated September 26, 2024, which had dismissed the appeal as withdrawn. Consequently, D.B. Income Tax Appeal No. 59/2020 was restored to its original number. The reasoning was based on the applicant's submission that the case was not covered by the CBDT circular dated September 17, 2022, and fell under an exception in the circular dated March 15, 2024. The court also noted that liberty had been granted for revival. The operative direction is the restoration of the main appeal.
The High Court of Judicature for Rajasthan, Bench at Jaipur, dismissed the writ petition. The primary reason for the dismissal was that the learned counsel for the petitioner pleaded 'no instruction' in the matter. This signifies that the petitioner's legal representative was unable to present any arguments or guidance on behalf of the petitioner. Consequently, the Court found itself unable to proceed with the case on its merits. The judgment does not delve into the substantive issues that might have been raised in the writ petition. The operative direction was to dismiss the writ petition and consign it to the record. No issues were expressly left undecided, as the petition was disposed of on a procedural ground.
The Tribunal held that the impugned order rejecting the condonation application was legally unsustainable. It found that all three substantive conditions stipulated in CBDT Circular No. 17/2024 were satisfied. Specifically, the return of income was filed on time, the option under Section 115BAA was exercised in the ITR-6, and the assessee was prevented by reasonable cause (oversight/mistake acknowledged before the AO) from filing Form 10-IC on time. Crucially, Form 10-IC was filed on 30.01.2023, which was within the three-year window from the end of AY 2020-21, and well within the period contemplated by Circular No. 17/2024 (cut-off 31.03.2024). The Tribunal noted that the impugned order conflated the date of filing Form 10-IC (30.01.2023) with the date of filing the condonation application (28.12.2024). The Tribunal concluded that denying the benefit due to a procedural technicality would defeat a substantive right. The writ petition was allowed, the impugned order was set aside, and the delay in filing the declaration and Form 10-IC was condoned. The matter was remanded to the competent authority for a fresh decision on merits, without considering the issue of delay or limitation.
The High Court held that the impugned notice dated 23.03.2026 issued under Section 148 of the Income Tax Act, 1961, and the sanction note dated 20.03.2026 are illegal, arbitrary, and without jurisdiction. The Court found that the basis for reopening the assessment was the same discrepancy regarding interest income that had already been considered and conclusively adjudicated by the Commissioner of Income Tax (Appeals) in its order dated 04.12.2025, which had attained finality. The Revenue had not challenged this appellate order. Therefore, there was no fresh information suggesting escapement of income. The Court emphasized that reassessment proceedings cannot be initiated based on a mere 'change of opinion' on facts and materials already available and examined during the original assessment or appellate proceedings. Citing Supreme Court and High Court precedents, the Tribunal concluded that the Assessing Officer was seeking to reopen a concluded matter without any new tangible material, which amounts to a collateral attack on a final adjudication and is impermissible. The reassessment notice was quashed.
The High Court noted that the issue involved in the present petition had already been considered and decided by the Court in the matter of Pramod Jain Vs. Additional Commissioner of Income Tax (D.B. Civil Writ Petition No.18359/2025) and connected matters, decided on 27.01.2025. Considering the submission of the learned counsel for the petitioner, the Court held that the present appeal stands disposed of in view of the judgment passed by this Court in the matter of Pramod Jain Vs. Additional Commissioner of Income Tax (supra). The ratio decidendi is that if a matter is covered by a previous judgment of the same court, it should be disposed of accordingly. All pending applications, if any, were also disposed of.
The High Court dismissed the writ petition. The Court noted that the respondent had filed an affidavit regarding the service of the assessment order as directed. However, the petitioner failed to file a counter-affidavit to dispute the service. Given the absence of a counter-affidavit and the respondent's compliance with the Court's direction to provide material regarding service, the Court found no basis to proceed with the writ petition. The Court granted liberty to the petitioner to file an appeal against the assessment order, implying that the appropriate remedy for challenging the assessment order, especially when service is disputed, lies in the appellate process. The issue of whether the order was actually served was not definitively decided on merits but was treated as not sufficiently controverted by the petitioner.
The High Court held that the present case does not fall within Exception 3.1(h) of the Circular dated March 15, 2024. Consequently, no case for interference was made out. The Court found no reason to deviate from the general principle that appeals with a tax effect below ₹2 crores are not to be preferred, as the specific exception cited by the Revenue was not applicable. The appeal was therefore dismissed. No issue was expressly left undecided.
The High Court held that the writ petition was not maintainable due to the existence of an alternative remedy of appeal before the Income Tax Authority. The Court reasoned that a writ petition under Article 226 of the Constitution is an extraordinary remedy and is generally not entertained when an equally efficacious alternative remedy is available to the aggrieved party. The principle is that statutory remedies should be exhausted before approaching the writ court. Therefore, the Court disposed of the writ petition, granting liberty to the petitioner to avail the alternative remedy. No specific issue was left undecided, as the petition was disposed of on a preliminary ground.
The High Court held that the writ petition had become infructuous. The reasoning was based solely on the submission made by the petitioner's counsel that the matter had become infructuous due to the passage of time. Consequently, the Court dismissed the writ petition on this ground. No decision was made on the merits of the original challenge that led to the filing of the writ petition. All pending applications were also disposed of.
The Tribunal held that the assessee's claim for interest on the tax refund arising from the set-off of brought forward losses of Rs. 5,53,13,531/- for A.Y. 1993-94 was not legally sustainable. The reasoning was that the previous ITAT order dated 23.01.2008, which had attained finality, clearly held that the assessee would not be entitled to interest on the tax refund to the extent it was covered under the KVSS declaration. The Tribunal found that the CIT(A) had misconstrued and acted contrary to this earlier ITAT order. The Tribunal also noted that the amount of disputed interest aggregated to Rs. 20.30 crores under KVSS, and the interest payable on the refund could not have exceeded this liability. Therefore, the assessee was not entitled to any interest on the tax refund relatable to the set-off amount. The question of law was answered accordingly, and the appeal was dismissed.
The High Court held that the learned ITAT erred in directing the refund of tax on the brought forward loss for AY 1993-94. While the ITAT correctly recognized the conclusiveness of a certificate issued under the KVSS, it contradicted itself by directing a refund. The court reasoned that allowing a refund on account of a brought forward loss would necessitate a reduction in the income tax demand for AY 1995-96, thereby reopening the conclusive settlement evidenced by the KVSS certificate. This recourse is impermissible under Section 90(3) of the Finance (No. 2) Act, 1998, which bars reopening matters covered by the KVSS order in any proceeding. Such a reduction would also undermine the finality and integrity of the KVSS settlement, which allowed the assessee to settle a substantial demand (Rs. 50,30,76,207/- for AY 1995-96) by paying a lesser amount (Rs. 16,84,14,519/-). Therefore, the Tribunal was not justified in directing the AO to refund tax attributable to the brought forward loss. For AY 1993-94, the Revenue's appeal was dismissed. For AY 1995-96, the Revenue's appeal was allowed, setting aside the ITAT's direction for refund.
The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly being adjudicated by the Supreme Court in Siddharth Totuka, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Supreme Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Supreme Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of the order passed in Pramod Jain (supra), with the observations and directions applying mutatis mutandis.
The High Court held that the learned ITAT erred in directing a refund of tax on the brought forward loss for AY 1993-94. While the ITAT correctly acknowledged the conclusiveness of a certificate issued under KVSS, its subsequent direction for a refund contradicted this principle. The Court reasoned that refunding tax on the brought forward loss would necessitate a reduction in the income tax demand for AY 1995-96, thereby reopening the conclusive settlement evidenced by the KVSS certificate. This recourse is impermissible under Section 90(3) of the Finance (No. 2) Act, 1998, which bars reopening matters covered by a KVSS order. Such a reduction would undermine the finality of the settlement and grant an undue benefit to the assessee, who had already settled a substantial demand for a significantly lesser amount. Therefore, the ITAT was not justified in directing the AO to refund tax attributable to the brought forward loss. For AY 1995-96, the Revenue's appeal was allowed, setting aside the ITAT's direction for refund. The Revenue's appeal for AY 1993-94 was dismissed.
The High Court held that given the narrow compass of the issue being directly adjudicated by the Hon'ble Apex Court in a related matter concerning Section 153C of the Income Tax Act, 1961, it was appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. The Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioner, nor give effect to any consequential orders or impugned orders, for as long as the interim protection granted by the Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) was declared to govern the outcome of the present petition. No specific issue was left undecided, as the petition was disposed of based on the Apex Court's interim order.
The High Court held that since the narrow compass of the issue was directly being adjudicated by the Hon'ble Apex Court in the matter of Siddharth Totuka (SLP No. 31711/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including consequential orders and giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of on this basis. No specific issue was left undecided, but the final decision on the merits of the Section 153C proceedings is deferred pending the Apex Court's decision.
The Tribunal held that the respondents do not have the authority to seize money (including cash) and securities during a search under Section 67(2) of the CGST Act, 2017. The Court reasoned that the legislature specifically excluded money and securities from the power of seizure granted to the respondents or the proper officer. Therefore, any seizure of money under Section 67(2) is illegal and without authority of law. The Court followed a series of High Court judgments (Delhi, Kerala, Gujarat) that have interpreted "things" in Section 67(2) as not encompassing ordinary currency. The ratio is that the power of search under Section 67(2) cannot be converted into a general authority to seize money and securities; there must be a demonstrable statutory basis and a proximate nexus between the property sought to be seized and the proceedings under the CGST Act. The mere presence of currency, an allegation of it being unaccounted, or an inability to explain its source, does not alone justify seizure under Section 67(2). The Court directed the respondents to return and refund the money seized from the petitioners without any delay. However, the Court was not inclined to grant compensation or interest on the seized money. Any other issues raised in connected writ petitions were left open.
The High Court held that the issuance of notice under Section 153C of the Income Tax Act, 1961, was vitiated due to the absence of incriminating material found during the search. The Court emphasized that for completed or unabated assessments, additions cannot be made under Section 153C without incriminating material found during a search under Section 132 or requisition under Section 132-A. The mere possession of documents belonging to another assessee does not automatically make them incriminating or a basis for initiating proceedings under Section 153C. The Court found that the AO had reassessed income for AY 2007-08 based on a transaction already known during the original assessment, and the recourse to Section 153C was not available for correction without new incriminating material. The Court also held that the sale of rural agricultural land, used for agricultural operations and not frequently traded, could not be treated as an adventure in the nature of trade or fall within the definition of capital gains under Section 2(14) of the Act. The Court quashed all three orders: the AO's order dated 28.12.2010, the CIT(A)'s order dated 27.02.2013, and the ITAT's order dated 06.12.2018. Both questions of law were answered in favour of the appellant.
The Tribunal held that proceedings initiated under Section 148A of the Income Tax Act, 1961, by issuing notices against a deceased person are a nullity. This legal position is no longer res integra, having been decided by previous Division Bench orders of the same Court. Specifically, the Court referred to its decisions in Shri Radha Mohan Khandelwal Vs. Assistant Commissioner of Income Tax and Legal Heirs of Smt. Sneh Lata Bhandari Vs. Income tax Officers & Ors. The reasoning is that notices and proceedings against a dead person are fundamentally flawed. The Court granted liberty to the Department to re-initiate proceedings under Section 148A(b) and Section 159 of the IT Act. The limitation period between the filing of the writ petition and its disposal was to be excluded for computing the limitation period for such re-initiated proceedings. The writ petition was allowed on these terms, permitting the Department to proceed in accordance with law against the legal representatives.
The High Court disposed of the writ petition with a specific direction to the appellate authority. The appellate authority was instructed to decide the appeal filed by the petitioner within a period of three months from the date of the order. The court's reasoning was based on the petitioner's submission that the appeal was pending for a long time and the revenue's lack of objection. The ratio decidendi is that courts can direct subordinate appellate authorities to expedite the disposal of pending appeals when there is an undue delay and no objection from the other side. The operative direction was to decide the appeal within three months. No issues were left undecided.
The High Court noted that the counsel for the petitioner wished to withdraw the writ petition. Consequently, the Court ordered the dismissal of the D.B. Civil Writ Petition No. 2325/2022 as withdrawn. Any pending miscellaneous applications were also disposed of. The judgment does not delve into the merits of the case or provide any substantive findings on the underlying tax dispute. The operative direction is solely to dismiss the petition as withdrawn.
The Tribunal held that ignorance of law is not a valid ground for condonation of delay under Section 119(2)(b) of the Income Tax Act, 1961. The court referred to the principle of 'ignorantia juris non excusat' (ignorance of law is not an excuse) and cited judgments from the Delhi High Court in Manjit Singh Dhaliwal Vs. Commissioner Of Income Tax International Taxation and Sanjay Khurana v. Income Tax Department Ministry of Finance. The Tribunal found that genuine hardship, as contemplated for condonation, requires real, unavoidable financial or practical difficulties arising from extraordinary circumstances beyond the assessee's control. The petitioner failed to demonstrate such hardship, and their claim of ignorance of law was not sufficient to establish bonafide with evidence. Therefore, the PCIT rightly disallowed the condonation of delay. The judgment in G.V. Infosutions Pvt. Ltd. was deemed not applicable in this case. The writ petition was dismissed.
The High Court held that the writ petition had become infructuous due to the efflux of time. The learned counsel for both the petitioner and the respondents made a joint submission to this effect. Consequently, the Court dismissed the writ petition on the grounds that it had become infructuous. The reasoning was based solely on the parties' agreement that the matter was no longer alive or relevant due to the passage of time. No decision was made on the substantive merits of any tax-related issue. All pending applications associated with the writ petition were also disposed of.
The High Court held that the writ petitions had become infructuous. The counsel for the petitioners made a submission to this effect. Based on this submission, the Court proceeded to dismiss the writ petitions. The reasoning is that if the parties themselves acknowledge that the matter is no longer a live dispute, and the relief sought is no longer capable of being granted or is otherwise rendered moot by the passage of time, the court will not adjudicate on the merits. The ratio decidendi is that writ petitions that have become infructuous are to be dismissed as such. The operative direction was the dismissal of all the writ petitions.
The High Court held that the writ petitions had become infructuous. The reasoning provided is solely based on the submission made by the counsel for the petitioners that the petitions had become infructuous due to the efflux of time. Consequently, the Court dismissed the writ petitions on this ground. No decision was made on the merits of any underlying tax dispute. The ratio decidendi is that if a petition becomes infructuous due to the passage of time, it should be dismissed on that basis without delving into the substantive issues.
The High Court held that the writ petitions had become infructuous. This decision was based solely on the submission made by the counsel for the petitioners. The court accepted this submission without delving into the merits of the underlying tax disputes. Consequently, the High Court dismissed the writ petitions. No specific findings were made on any tax-related issues, and no operative directions were issued regarding the tax assessments themselves. The principle derived from this judgment is that a writ petition can be dismissed as infructuous if the parties agree that it has lost its purpose due to the passage of time or other supervening circumstances.
The High Court held that the writ petitions had become infructuous. This decision was based solely on the submission made by the counsel for the petitioners. The court accepted this submission without delving into the merits of the underlying tax disputes. Consequently, the High Court dismissed the writ petitions. No specific findings were made on any tax-related issues, and no operative directions were issued regarding the tax assessments themselves. The principle derived from this judgment is that a writ petition can be dismissed as infructuous if the parties agree that it has lost its purpose due to the passage of time or other supervening circumstances.
The High Court held that the writ petitions have become infructuous due to the efflux of time. Consequently, the Court dismissed the writ petitions on this basis. The reasoning provided is solely based on the submission made by the petitioners' counsel. No other issues were decided, and no findings were made on the merits of the original challenges to the income tax authorities' actions. The operative direction was the dismissal of the petitions.
The High Court held that the first question of law regarding the disallowance under Section 36(1)(iii) is answered in favor of the respondent. The Court noted that the subsidiary/sister concerns are engaged in the same line of business as the respondent, furthering common business objectives. The issue of commercial expediency constitutes a pure finding of fact, duly recorded by the CIT(A) and affirmed by the ITAT. As no substantial question of law arises from this finding, no interference is warranted. The Court also referred to Supreme Court judgments in Sharp Business System and S.A. Builders Ltd. in this regard. Regarding the second question of law concerning the disallowance under Section 40(a)(ia), the Court found it pertains purely to findings of fact with no question of law involved. The Court was satisfied that the ITAT's conclusions were based on proper appreciation of evidence and found no infirmity in the deletion of disallowance. Therefore, this question is also answered in favor of the respondent. The appeals are dismissed.
The High Court held that the issue involved in the present writ petition is no longer res integra and has been resolved by a Co-ordinate Bench order dated 22.03.2024 in the case of Meena V Kumar Vs. Principal Chief Commissioner of Income Tax (D.B. Civil Writ Petition No.15115/2022). Consequently, the Court ordered the disposal of the instant writ petition in terms of that order. The reasoning is based on the principle of judicial precedent, where a decision of a Co-ordinate Bench on a similar issue is binding. The ratio decidendi is that if an issue has been authoritatively decided by a Co-ordinate Bench, subsequent similar matters should be disposed of in accordance with that decision. The operative direction was to dispose of the writ petition accordingly. No issue was expressly left undecided.
The Tribunal found that the AO had conducted a detailed inquiry and reached a conclusion. The High Court agreed that the AO's order was not erroneous or prejudicial to the revenue, and thus the CIT(TDS) order under Section 263 was not justified.
The High Court, in respectful agreement with a co-ordinate bench's view, dismissed the appeal. The Court noted that the net tax effect involved was Rs. 54,168/-, which is significantly below the prescribed monetary threshold for filing appeals before the High Court as per CBDT Circular No. 05/2024. The Court held that in view of this circular and the policy of reducing unnecessary litigation, the appellant is under a legal obligation not to press such claims on merits. The question of law raised in the appeal was kept open to be adjudicated in appropriate proceedings in the future. No specific finding was made on the merits of the ITAT's decision.
The High Court dismissed the appeals, upholding the ITAT's decision. It affirmed that an assessment based on third-party statements without allowing cross-examination violates natural justice and renders the order a nullity. The court found no substantial question of law arose, noting that the ITAT had satisfactorily dealt with the factual aspects of the assessee's transactions.
The High Court dismissed the appeals, upholding the ITAT's decision. It affirmed that an assessment based on third-party statements without allowing cross-examination violates natural justice and renders the order a nullity. The court found no substantial question of law arose, noting that the ITAT had satisfactorily dealt with the factual aspects of the assessee's transactions.
The High Court dismissed the appeals, upholding the ITAT's decision. It affirmed that an assessment based on third-party statements without allowing cross-examination violates natural justice and renders the order a nullity. The court found no substantial question of law arose, noting that the ITAT had satisfactorily dealt with the factual aspects of the assessee's transactions.
The High Court found that the ITAT's decision regarding the invalidity of the notice due to procedural non-compliance with Section 151 was correct. They concluded that no substantial question of law arose for their consideration.
The Court noted that the learned counsel for the petitioner prayed to withdraw the writ petition as it had become infructuous. Consequently, the Court dismissed the Civil Writ Petition as having become infructuous. All pending applications were also disposed of. The judgment does not provide any reasoning beyond the petitioner's submission that the matter was infructuous.
The High Court held that since the narrow compass of the issue was directly being adjudicated by the Hon'ble Apex Court in the litigation pertaining to Section 153C of the Income Tax Act, 1961, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Consequently, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) was declared to govern the outcome of the present petitions. The writ petitions were disposed of in terms of the order passed in the case of Pramod Jain, with the observations and directions applying mutatis mutandis.
The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court, it was appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. The Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioner, nor give effect to any consequential orders or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) was declared to govern the outcome of the present petition. No specific issue was left undecided; the Court deferred to the Apex Court's decision.