High Court expedites petitioner's appeals under Section 250(6A) of Income Tax Act, 1961. Respondent ordered to review within three months.

The High Court prioritized the petitioner's appeals for expeditious consideration under Section 250(6A) of the Income Tax Act, 1961, due to the significant impact on the petitioner's tax liability. The Court directed the respondent to review and dispose of the appeals within three months, emphasizing timely resolution without ruling on costs.

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Issues:
Petitioner seeking writ of mandamus for expeditious consideration of appeals for Assessment years [2013-14, 2014-15 & 2015-16] under Section 250(6A) of Income Tax Act, 1961.

Analysis:
The petitioner filed writ petitions seeking a writ of mandamus to direct the respondent to expedite the consideration of appeals for the Assessment years [2013-14, 2014-15 & 2015-16] under Section 250(6A) of the Income Tax Act, 1961. The petitioner highlighted that the disallowance of reimbursement paid to its subsidiary abroad by the Assessing Officer was causing an increasing financial burden due to the growing business. The petitioner emphasized the cascading effect of the pending proceedings on its tax liability. Additionally, it was argued that the petitioner had a strong case on merits, which, if reviewed by the Appellate Commissioner, could potentially resolve the dispute promptly.

During the proceedings, both the counsel for the petitioner and the Senior Standing Counsel for the respondent presented their arguments. The Senior Standing Counsel for the respondent requested time to file a counter, but assured that if a reasonable timeframe was set, the respondent would strive to pass orders based on merits. The petitioner had filed appeals for the relevant Assessment years on different dates in the past.

The High Court acknowledged that the issues arising from the appeals had a significant impact on the petitioner's tax liability for subsequent years. Recognizing the recurring nature of the issues, the Court deemed it necessary to prioritize the petitioner's appeals for early resolution. Without expressing any opinion on the case's merits, the Court disposed of the writ petitions.

Considering the arguments put forth by both parties, the Court directed the respondent to review and dispose of the appeals on their merits and in compliance with the law within three months from the date of receiving a copy of the order. The Court made no ruling on costs in this matter.

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