Section 197 application delays require expeditious disposal; writ relief was deferred pending statutory revision remedy.

A grievance over non-consideration and delay in disposing of an application under Section 197 of the Income-tax Act, 1961 was not finally adjudicated, as the petitioner was first directed to pursue the statutory revision remedy. The Court noted prima facie that such applications should be dealt with expeditiously and that alleged non-entertainment before 1 April 2013 was not the proper approach, but it did not decide the merits of the controversy. The writ petition was disposed of with liberty to the petitioner to return if there was further delay or an adverse order.

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Issues: Whether the petitioner's grievance regarding non-consideration of its application under Section 197 of the Income-tax Act, 1961 and delay in disposal warranted immediate adjudication by the Court.

Analysis: The Court recorded the petitioner's grievance that substantial refunds had become due because of excess tax deducted at source and that the application under Section 197 had allegedly not been entertained before 1 April 2013. It observed prima facie that such an approach should not be followed and that expeditious disposal of such matters is required. The Court, however, did not enter into a final adjudication on the merits of the controversy and instead directed the petitioner to pursue the statutory revision remedy first.

Outcome: The writ petition was disposed of with liberty to the petitioner to approach the Court again in case of delay or an adverse order.

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