Contempt proceedings and prospective tax amendment: no wilful disobedience found after the grievance was substantially addressed.

The contempt petition concerned whether respondents had wilfully disobeyed an earlier order directing reconsideration of the statutory provision after a later amendment to Section 80DD of the Income-tax Act, 1961. The Court noted that the grievance underlying the petition had been substantially addressed by the 2022-2023 Budget amendment, although the benefit operated prospectively. On that basis, the alleged non-compliance did not amount to wilful disobedience, and any further grievance could not be pursued through contempt proceedings. No contempt was made out, and the petition was closed.

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Issues: Whether the respondents were liable for contempt for not complying with the earlier order directing reconsideration of the statutory provision, in light of the subsequent amendment to Section 80DD of the Income-tax Act, 1961.

Analysis: The grievance that formed the basis of the contempt petition stood substantially addressed by the amendment brought in through the Budget of 2022-2023, though the benefit operated prospectively. In these circumstances, the alleged non-compliance did not disclose wilful disobedience of the earlier order. Any further grievance could not be pursued in contempt proceedings.

Conclusion: No contempt was made out against the respondents and the contempt petition was closed.

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