Facts of the Case

  1. The petitioner company approached the Delhi High Court by way of writ petitions against the Income Tax Department.
  2. The dispute was connected with income tax proceedings pending against the petitioner.
  3. During the pendency of the writ petitions, appellate proceedings before the Commissioner of Income Tax (Appeals) resulted in orders dated 15 December 2016 and 09 January 2017.
  4. These appellate orders effectively addressed the grievance forming the subject matter of the writ petitions.
  5. As a result, the writ petitions lost their substantive cause of action and became infructuous.

 Issues Involved

  • Whether the writ petitions survive after the appellate authority (CIT(A)) has passed orders covering the grievance of the petitioner?
  • Whether judicial intervention under writ jurisdiction is required when the relief sought has already been addressed in appellate proceedings?

 Petitioner’s Arguments

  • The petitioner initially sought judicial intervention against the actions of the Income Tax Department.
  • During the hearing, learned counsel for the petitioner submitted that the reliefs sought in the writ petitions had become infructuous due to subsequent appellate orders passed by the CIT(A).

 Respondent’s Arguments

  • The Income Tax Department appeared through its counsel and defended the proceedings.
  • In view of the subsequent appellate developments, the respondents’ position stood aligned with the disposal of the petitions as infructuous.

 Court Findings / Order

The Delhi High Court observed that in view of the appellate orders passed by the Commissioner of Income Tax (Appeals), the relief claimed in the writ petitions no longer survived for adjudication. Accordingly, the Court dismissed/disposed of the writ petitions as infructuous.

 Important Clarification

This judgment reiterates that when the grievance raised in a writ petition stands addressed by subsequent statutory appellate proceedings, the writ jurisdiction may not be invoked further, and the petition may be treated as infructuous. This reflects the principle of judicial economy and procedural efficiency.

 Sections Involved

  • Sections 13 & 14 (as recorded in the order heading)
  • Proceedings arising under the Income Tax framework involving appellate orders of the Commissioner of Income Tax (Appeals) [CIT(A)].

Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2017:DHC:8122-DB/SRB08032017CW49822015_155900.pdf

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