SC Allows Withdrawal of SLP; Petitioner Can Seek PAN Rectification Under Income Tax Act's Section 119 with CBDT Promptly.

The SC permitted the withdrawal of a Special Leave Petition, granting the petitioner liberty to make a representation to the CBDT under Section 119 of the Income Tax Act, 1961, for adjustment concerning a PAN rectification. The SC directed that the representation be considered promptly and on its own merits, independent of previous rejections.

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Issues involved:
The issues involved in the judgment are withdrawal of Special Leave petition with liberty to make representation to CBDT under Section 119 of the Income Tax Act, 1961 for seeking adjustment in view of rectification made by the Department regarding PAN number.

Withdrawal of Special Leave Petition:
The petitioner's senior counsel requested permission to withdraw the Special Leave petition with liberty to make a representation to the Central Board of Direct Taxes (CBDT) under Section 119 of the Income Tax Act, 1961. The Court dismissed the Special Leave Petition as withdrawn, reserving the liberty to the petitioner to seek adjustment in light of the rectification made by the Department concerning the PAN number.

Consideration of Representation to CBDT:
The Court emphasized that any representation made by the petitioner to the CBDT should be considered expeditiously and in accordance with the law. It was specifically mentioned that the representation shall be evaluated on its own merits without being influenced by the earlier rejection of the petitioner's plea in the proceedings on the grounds of delay and not on merits.

This judgment highlights the process of withdrawing a Special Leave petition with liberty granted to the petitioner to approach the CBDT for seeking adjustment following rectification by the Department. The Court ensured that any representation made to the CBDT would be considered independently of the previous rejection, emphasizing expeditious consideration and adherence to legal principles.

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