Facts of the Case

The petitioners filed multiple writ petitions before the Delhi High Court challenging issues relating to non-issuance or incorrect issuance of Form-3 by the Income Tax Department under the applicable tax dispute resolution scheme.

During the pendency of the writ petitions, the respondents issued revised Form-3 to the petitioners in accordance with their claims and prayer clauses.

Issues Involved

  1. Whether the writ petitions survive after issuance of revised Form-3.
  2. Whether the grievance of the petitioners stands redressed by subsequent compliance of the department.

Petitioner’s Arguments

  • The petitioners initially approached the Court due to deficiencies or non-compliance by the department in issuing Form-3.
  • They sought directions for issuance/correction of Form-3 as per statutory entitlement.

Respondent’s Arguments

  • During proceedings, the department complied with the petitioners’ claims.
  • Revised Form-3 was issued, thereby addressing the grievances raised in the writ petitions.

Court’s Findings / Order

  • The grievances of the petitioners stood resolved since revised Form-3 had been issued.
  • The writ petitions had become infructuous.
  • Accordingly, all petitions were disposed of as satisfied.

Important Clarification

  • Once the relief sought in a writ petition is granted during pendency, the petition becomes infructuous.
  • Courts will not adjudicate academic or redundant issues when no live dispute remains.
  • Compliance by the department during proceedings can lead to disposal without further adjudication.

Relevant Sections Involved

  • Income Tax Act, 1961
  • Provisions relating to dispute resolution scheme (Form-3 issuance under Vivad Se Vishwas Scheme or similar compliance framework)

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

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