Adjournment Sine Die cannot substitute for a decision; reserved appeals must be decided or protective steps taken without indefinite delay.

Adjournment sine die of an appeal after hearing and reservation was held improper where a reserved judgment remains operative; the Tribunal must either decide the appeal within the prescribed time frame or take explicit protective measures if further delay is indispensable. Rule 34(5)(c) contemplates time bound delivery of judgment and its directory character does not permit rendering the appellant's remedy ineffective by indefinite adjournment merely because a separate appeal was admitted and questions of law were framed. Absent a stay of the Tribunal's order, admission of another appeal does not automatically justify sine die adjournment; the impugned adjournment was set aside and the appeal must be decided in accordance with law.

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Issues: Whether the Income Tax Appellate Tribunal was legally justified in adjourning the petitioner's appeal sine die after reserving order, solely because a separate appeal (ITA No.30/2025) had been admitted and questions of law framed, without staying the effect of its order.

Analysis: The petition challenges the Tribunal's decision to adjourn the appeal sine die after the matter had been heard and the order reserved. Relevant procedural prescription includes Rule 34(5)(c) of the Income Tax Appellate Tribunal Rules, 1963, which contemplates a time-bound delivery of judgment (sixty days, extendable by thirty days). The issue of admission of a separate appeal and framing of substantial questions of law does not, without an order staying the operation of the Tribunal's order, automatically justify indefinite adjournment where the reserved judgment remains operative. Directory character of procedural time-limits does not permit a bench to render the appellant's grievance ineffective by adjourning sine die once the appeal has been heard and the stay application refused; the Tribunal had the duty to either decide the appeal or take steps to protect the assessee's interest if it considered delay necessary.

Conclusion: The adjournment of the appeal sine die is set aside and the Tribunal is directed to decide the appeal in accordance with law within the specified time frame. The decision is in favour of the assessee.

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