SC dismisses Revenue’s appeal for unexplained delay and lack of merit

ACIT Vs Mamta Agarwal (Supreme Court of India)

Supreme Court of India, in the case of ACIT vs Mamta Agarwal, dismissed the Special Leave Petitions (SLPs) filed by the Revenue, challenging the order passed by the Delhi High Court in WP(C) No. 853/2024. The Revenue sought to overturn the High Court’s judgment dated April 9, 2024, but the apex court refused to intervene, citing procedural and substantive reasons.

A significant factor in the dismissal was the substantial delay of 142 and 172 days in filing the SLPs. The court observed that the Revenue failed to provide a satisfactory explanation for this delay, which constituted a gross procedural lapse. The Supreme Court emphasized the importance of adhering to statutory timelines to ensure the expeditious resolution of disputes, as highlighted in earlier precedents such as Office of the Chief Postmaster General vs Living Media India Ltd. (2012), where delays caused by administrative inefficiencies were not condoned.

Apart from procedural lapses, the Supreme Court also found no substantive grounds to interfere with the Delhi High Court’s decision on merits. The High Court had addressed the issues raised by the Revenue and ruled in favor of the taxpayer, Mamta Agarwal, thereby granting relief. The apex court, after reviewing the case, concluded that there were no compelling legal errors warranting its intervention.

This dismissal reaffirms the principle that judicial remedies should not be delayed by administrative inaction or inefficiency. The Supreme Court’s reliance on precedents underscores the need for prompt and diligent action by the Revenue authorities in filing appeals. Pending applications related to the case were also disposed of.

FULL TEXT OF THE SUPREME COURT JUDGMENT/ORDER

[Arising out of impugned final judgment and order dated 09-04-2024 in WP(C) No. 853/2024 passed by the High Court of Delhi at New
Delhi]

1.  Heard the learned Additional Solicitor General appearing for the petitioners – Revenue.

2.  There is a gross delay of  142 and 172 days respectively  in filing the   Special   Leave   Petitions   which   has   not   been satisfactorily explained by the petitioners.

3. Even otherwise, we see no reason to interfere with the impugned order passed by the High Court.

4. The Special Leave Petitions are, accordingly, dismissed on the ground of delay as well as merits.

5. Pending applications, if any, shall also stand disposed of.