Delay in disposing income-tax appeal violates natural justice; HC directed early consideration, reasoned order, and hearing.

Non-compliance with a prior judicial direction to decide an income-tax appeal was treated as prima facie unacceptable, as continued administrative inaction could not deny an effective remedy or a hearing. The Calcutta HC noted that the pending appeal had remained undecided for an extended period despite an earlier order requiring a speaking order, and regarded the delay as inconsistent with natural justice and the constitutional requirement of fair, speedy justice under Article 14. The respondent was therefore directed to consider the application for early disposal within six weeks, pass a reasoned order after hearing the assessee, and communicate the decision within one week thereafter; the writ petition was disposed of without examining the merits.

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Issues: Whether the writ petition challenging non-compliance with a prior direction to decide the pending income-tax appeal could be entertained and whether a time-bound direction for disposal was warranted.

Analysis: A prior order had directed the appellate authority to pass a speaking order in the assessee's appeal for assessment year 2015-16, but the appeal remained pending for an extended period. The Court found prima facie that such continued inaction amounted to non-compliance of a binding judicial order and that administrative delay could not deprive the assessee of an effective remedy. The delay was treated as inconsistent with natural justice and the right to speedy justice under Article 14 of the Constitution of India.

Outcome: The respondent was directed to consider the application for early disposal within six weeks, pass a reasoned order after giving an opportunity of hearing, and communicate the decision within one week thereafter; the writ petition was disposed of without entering into the merits.

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