The Supreme Court has strongly criticised the Income Tax Department for filing a Special Leave Petition (SLP) in a matter that the Court said was already conclusively settled in earlier rulings. Terming the appeal frivolous and unnecessary, the Bench observed that the Department’s practice of repeatedly challenging issues that have attained finality only adds to the judiciary’s burden and causes needless hardship to taxpayers.
The Court noted that the question raised in the SLP had been answered several times in previous judgments, leaving no ambiguity in law. Despite this clarity, the Department chose to file yet another appeal. The Bench cautioned that such conduct reflects a disregard for litigation-management principles and undermines judicial efficiency.
Emphasising that government departments must act responsibly while approaching the Court, the judges remarked that the Income Tax Department should avoid “mechanical, repetitive, and purposeless” filings. They reiterated that public authorities have an obligation to prevent avoidable litigation and to respect the finality of decisions once legal issues stand conclusively settled.
This observation serves as a strong signal to tax authorities to rethink their approach to appeals and adopt a more disciplined, rational litigation strategy. For taxpayers, the ruling reinforces the principle that once the Supreme Court has settled a question of law, revenue authorities cannot continue to reopen the same issue through repeated SLPs.
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