Facts of the Case

The assessee, Shramik Vidyapeeth, Ranchi, filed an appeal against the order dated 14.02.2025 passed by the Additional/Joint Commissioner of Income Tax (Appeals), Thiruvananthapuram for Assessment Year 2013-14. During the pendency of the appeal, the assessee filed a letter dated 08.05.2025 before the Tribunal explaining that the Assessing Officer had passed a rectification order under Section 154 of the Income-tax Act granting the requisite relief. The rectification order corrected errors in the intimation processed earlier and recomputed income and tax liability accordingly.

Issues Involved

Whether the appeal before the Tribunal survives once the assessee has already obtained complete relief through a rectification order under Section 154 of the Income-tax Act, and whether the appellate proceedings become infructuous in such circumstances.

Petitioner’s Arguments

The assessee submitted that subsequent to filing of the appeal, the Assessing Officer had passed an order under Section 154 rectifying the mistakes in the original assessment and granting full relief to the assessee. It was contended that as the grievance raised in the appeal stood fully redressed, the appeal no longer survived.

Respondent’s Arguments

The Revenue relied on the rectification order passed by the Assessing Officer and supported dismissal of the appeal as infructuous.

Court Order / Findings

The ITAT Ranchi observed that the assessee had obtained the requisite relief through the rectification order passed by the Assessing Officer under Section 154 of the Act. The Tribunal held that once the relief sought by the assessee had already been granted, the order of the appellate authority no longer survived. Consequently, the appeal filed by the assessee was rendered infructuous and liable to be dismissed.

Important Clarification

The Tribunal clarified that where the Assessing Officer grants complete relief by passing a rectification order under Section 154, any pending appeal on the same issue becomes infructuous, as there remains no subsisting cause of action for adjudication.

Final Outcome

The appeal filed by the assessee was dismissed as infructuous, as the assessee had already obtained full relief through the rectification order passed under Section 154 of the Income-tax Act.

Link to Download Order- https://www.mytaxexpert.co.in/uploads/1769080704_SHRAMIKVIDYAPEETHRANCHIVS.INCOMETAXOFFICEREXEMPTIONCIRCLERANCHIRANCHI.pdf

 

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