Facts of the Case

Multiple petitioners, including corporate entities and individuals, filed writ petitions before the Delhi High Court challenging issues relating to incorrect or disputed Form-3 issued by the Income Tax Department.

During the pendency of the petitions, the respondents (Income Tax Authorities) issued revised Form-3 to the petitioners in line with the reliefs sought in the writ petitions.

Issues Involved

  1. Whether the grievances raised in the writ petitions survived after issuance of revised Form-3.
  2. Whether the writ petitions required adjudication on merits after compliance by the department.

Petitioner’s Arguments

  • The petitioners initially challenged discrepancies/errors in Form-3 issued by the Income Tax Department.
  • Relief was sought for correction/reissuance of Form-3 in accordance with applicable provisions and entitlements.

Respondent’s Arguments

  • During proceedings, the respondents rectified the issue by issuing revised Form-3 to the petitioners.
  • It was implied that the grievance of the petitioners no longer subsisted after such compliance.

Court’s Findings / Order

  • The Court recorded that revised Form-3 had been issued to the petitioners in accordance with their prayer.
  • Consequently, the Court held that the writ petitions had become infructuous.
  • All writ petitions were disposed of as satisfied.

Important Clarification by Court

  • Once the relief sought by the petitioners is granted during pendency, the Court may treat the matter as infructuous without entering into merits.
  • Judicial time is not required to be spent on academic or resolved disputes.

Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2021:DHC:4480-DB/MMH25082021CW25842021_163205.pdf

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