Gopal Goyal Vs. DCIT (Rajasthan High Court)
Summary: The Rajasthan High Court, Jaipur Bench, in Gopal Goyal v. Deputy Commissioner of Income Tax & Others, D.B. Civil Writ Petition No. 2915/2021, along with D.B. Civil Writ Petition No. 10814/2021 involving Ravi Surya Developers Private Limited and other petitioners, passed a common order on 24 September 2025 disposing of both writ petitions in accordance with its earlier decision in Friends SPS International India (P) Ltd. & Others v. Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Others, D.B. Civil Writ Petition No. 3372/2021 and connected matters, decided on 26 March 2025. Both sides informed the Court that the controversy was no longer res integra, having already been resolved by a coordinate Bench.
The petitions concerned proceedings involving the Income Tax Settlement Commission and the Income Tax Department following changes to the settlement regime. The order itself did not independently examine the underlying statutory questions, the validity of the petitioners’ settlement applications or the substantive conditions for settlement. Instead, counsel for the respective parties jointly submitted that the controversy was covered by the earlier Rajasthan High Court decision and requested disposal of the pending matters on the same terms.
In the earlier Friends SPS International India decision, the coordinate Bench had considered the CBDT Order dated 28 September 2021 issued under Section 119(2)(b) of the Income-tax Act, 1961, which extended the filing period for specified income-tax settlement applications until 30 September 2021. That Bench had directed the Interim Board for Settlement to consider the applications in accordance with law while taking the CBDT Order into account. Importantly, it had expressly refrained from determining the applicants’ eligibility under Section 245C. The present Bench did not enlarge or alter those directions.
Accepting the submissions of both sides, the High Court ordered that the present writ petitions be disposed of in terms of the decision dated 26 March 2025. It further directed that all pending applications, if any, would also stand disposed of. Thus, the operative relief followed the previously decided Friends SPS International India matter. The present order did not independently grant settlement, determine the amount of any tax liability or finally adjudicate eligibility under the settlement provisions.
Cases Discussed
1. Friends SPS International India (P) Ltd. & Ors. v. Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors., 2025:RJ-JP:13797-DB, D.B. Civil Writ Petition No. 3372/2021 and connected matters, order dated 26.03.2025 (Rajasthan High Court) — Followed as the controlling coordinate Bench decision. The Court disposed of the present writ petitions in terms of that judgment, which had directed consideration of settlement applications by the Interim Board in accordance with law, taking into account the CBDT Order dated 28 September 2021.
FULL TEXT OF THE ORDER OF RAJASTHAN HIGH COURT
Learned counsel appearing for respective parties submit that the issue involved herein is no more res integra and stands resolved by a coordinate Bench of this Court vide order dated 26.03.2025 passed in the case of Friends SPS international India (P) Ltd. & Ors. versus Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors.: D.B. Civil Writ Petition No.3372/2021 and other connected matters, and prays for disposal of the instant matters in terms thereof.
Ordered accordingly.
Pending application(s), if any, also sands disposed of.
