Release of auctioned lands against deposited tax dues where no third-party rights existed, with questions of law left open.

Tax dues with accrued interest were deposited in Court in three connected civil appeals, and the Department had itself purchased the lands in auction without any third-party rights having been created. In these circumstances, the Court directed release of the deposited amount to the Department and required release of the lands to the appellants on receipt of that amount within the stipulated time. The appeals were disposed of without adjudication of the substantial questions of law, which were expressly left open.

---

---

Issues: Whether, on deposit of the income-tax dues with accrued interest before the Court, the appellants were entitled to release of the deposited amount and corresponding release of the lands by the Department.

Analysis: The amount of tax dues with interest had been deposited in Court in the three connected civil appeals. It was also noted that the Department itself had purchased the land through auction and that no third-party rights had been created in respect of the lands. In these circumstances, the Court found that the ends of justice would be met by directing release of the deposited amount to the Department and requiring the Department to release the lands on receipt of that amount within the stipulated time.

Conclusion: The appellants obtained the benefit of release of the lands against payment of the deposited tax dues, while the appeals were disposed of without adjudication on the substantial questions of law, which were left open.

---