Court disposes writ petition challenging income tax rejection order, Respondent assures 'Nil' deduction certificate, petitioner's concerns resolved.

The court disposed of the writ petition seeking the setting aside of the ex-parte rejection order by the Respondent Income Tax Department for a No deduction of Income Tax Certificate under section 197. The Respondents assured prompt uploading of the approval for a 'Nil' deduction certificate, resolving the petitioner's concerns. Consequently, the court acknowledged the resolution of the petitioner's grievances and disposed of the matter.

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Issues:
1. Rejection of application for No deduction of Income Tax Certificate u/s 197 of the Income Tax Act, 1961.
2. Delay in issuance of the certificate and subsequent rejection.
3. Liability to make payment and recovery of demands by the Income Tax Department.
4. Consideration of new application for 'Nil Deduction Certificate' under section 197 of the Income Tax Act, 1961.

Analysis:

1. The petitioner filed a writ petition seeking the setting aside of the ex-parte rejection order dated Nil passed by the Respondent Income Tax Department. The rejection was based on outstanding TDS/TCS demand and the non-acceptance of estimated profit projection due to post-COVID business conditions. The petitioner requested the immediate issuance of the No deduction of Income Tax Certificate u/s 197, emphasizing the delay of more than nine months and lack of consideration of submitted documents. The court was urged to declare the petitioner not liable for demands from 2008-09 to 2017-18, citing relevant judgments and approvals under the Insolvency and Bankruptcy Code, 2016.

2. The Respondent CIT (TDS), Patna, informed the court that approval for a 'Lower / Nil Deduction Certificate' under section 197 had been granted but faced technical issues in uploading the approval on the TRACES Portal. The Deputy Commissioner of Income Tax, TDS Circle, Ranchi, recommended a 'Nil' deduction certificate for the petitioner based on financial details and previous year's demands. The Respondents assured that the approval would be uploaded promptly, addressing the petitioner's concerns.

3. Considering the Respondent's commitment to issuing the 'Lower Deduction Certificate' and the technical delay in uploading the approval, the court acknowledged that the petitioner's grievances seemed resolved. The court disposed of the writ petition in light of the Respondent's actions and the satisfaction of the petitioner's concerns regarding the issuance of the certificate under section 197 of the Income Tax Act, 1961.

This detailed analysis highlights the issues raised in the judgment, the arguments presented by both parties, and the court's decision based on the resolution of the petitioner's grievances regarding the No deduction of Income Tax Certificate application.

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