Facts of the Case

The present batch of writ petitions was filed by multiple petitioners including Nimit Builders Private Limited and others challenging actions of the Income Tax Department, specifically the office of the Principal Commissioner of Income Tax-4 and others.

During the course of proceedings, it was submitted on behalf of the petitioners that the grievances raised in the writ petitions stood addressed as revised Form-3 had been issued to the petitioners in accordance with the prayer clauses.

Issues Involved

  1. Whether the relief sought in the writ petitions survives after issuance of revised Form-3.
  2. Whether the writ petitions become infructuous upon compliance by the Income Tax Department.

Petitioner’s Arguments

  • Learned counsel for the petitioners submitted that the reliefs sought in the writ petitions have already been granted.
  • It was specifically stated that revised Form-3 had been issued to the petitioners, satisfying the prayer clauses of the petitions 

Respondent’s Arguments

  • The order does not record detailed submissions of the respondents.
  • However, it is implied that the department had already complied with the relief sought by issuing revised Form-3.

Court’s Findings / Order

  • The Court recorded the submission made by the petitioners that the writ petitions had become infructuous.
  • It observed that since revised Form-3 had been issued, the grievance no longer survived.
  • Accordingly, the Court held:
    • The writ petitions are disposed of as satisfied.
    • No further adjudication was required.

Important Clarification

  • The Court did not go into the merits of the dispute.
  • Disposal was based solely on the fact that relief had already been granted administratively.
  • This order reinforces that writ jurisdiction may not be exercised where grievances are already redressed.

Sections Involved

(Though not expressly mentioned in the order, the matter pertains to Income Tax proceedings and likely involves:)

  • Provisions relating to Form-3 under the Income Tax Act, 1961
  • Principles governing writ jurisdiction under Article 226 of the Constitution of India

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

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