Rajasthan High Court Applies Coordinate Bench Ruling on Income Tax Settlement Petitions

Background of the Petitions

The Rajasthan High Court, Jaipur Bench, dealt with two writ petitions concerning the income tax settlement mechanism after legislative and procedural changes to the settlement regime. The matters were:

  • D.B. Civil Writ Petition No. 2915/2021 titled Gopal Goyal Vs. DCIT (Rajasthan High Court)
  • D.B. Civil Writ Petition No. 10814/2021 involving Ravi Surya Developers Private Limited along with other petitioners

On 24/09/2025, the Bench passed a common order disposing of both petitions together. The central issue related to proceedings involving the Income Tax Settlement Commission / Interim Board for Settlement and the Income Tax Department, particularly in light of the transition from the earlier Settlement Commission framework to the Interim Board regime and the relevant timelines for filing or pursuing settlement applications.

Core Issue Before the Court

The petitions essentially revolved around:

  • The continuation and consideration of settlement-related applications filed by the assessees
  • The impact of subsequent changes in law and administrative directions on such applications
  • The effect of the CBDT Order dated 28 September 2021 issued under Section 119(2)(b) of the Income Tax Act 1961, particularly in respect of the extended due date up to 30 September 2021 for specified categories of settlement applications

However, in this particular order dated 24/09/2025, the Rajasthan High Court did not undertake a fresh or detailed analysis of these substantive aspects. Instead, the focus was on the applicability of an already existing coordinate Bench judgment.

Reliance on Earlier Coordinate Bench Judgment

Both sides – counsel for the petitioners and the Revenue – jointly informed the Court that the controversy raised in these writ petitions was already covered by an earlier decision of a coordinate Bench of the same Court.

The earlier precedent cited and relied upon was:

  • Friends SPS International India (P) Ltd. & Ors. v. Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors.
  • Citation: 2025:RJ-JP:13797-DB
  • Case reference: D.B. Civil Writ Petition No. 3372/2021 and connected matters
  • Date of order: 26.03.2025

In that earlier decision, the coordinate Bench had examined the implications of the CBDT Order dated 28 September 2021 issued under Section 119(2)(b) and its effect on specified settlement applications filed up to 30 September 2021.

Directions in the Earlier Friends SPS International India Decision

In **Friends SPS International India (P) Ltd. & Ors. v.