SC Upholds CIRP Relief; Refuses to Interfere in Tax Dispute of Reliance Projects and Property Management Services

The dispute arose from assessment proceedings against Reliance Projects and Property Management Services Limited for Assessment Year 2018–19. The assessee had approached the Bombay High Court challenging various notices and orders issued by the Income Tax Department. Before the High Court, it was submitted that the issue was squarely covered by earlier decisions in similar matters, including cases where companies undergoing Corporate Insolvency Resolution Process (CIRP) were granted relief against tax proceedings. The Revenue did not dispute the applicability of those precedents. Accepting the submissions, the High Court quashed all impugned notices and consequential assessment orders. Aggrieved by the relief granted, the Revenue preferred a Special Leave Petition before the Supreme Court along with an application for condonation of delay.

Issue Raised: Whether the Supreme Court should interfere with the Bombay High Court’s order quashing assessment proceedings in light of binding precedents relating to CIRP and tax liabilities.

SC Held: The Supreme Court condoned the delay in filing the Special Leave Petition but declined to interfere with the impugned judgment of the Bombay High Court. After hearing the parties and examining the record, the Court found no merit in the Revenue’s challenge. Accordingly, the Special Leave Petition was dismissed, thereby affirming the High Court’s decision quashing the assessment proceedings and related notices. All pending applications were also disposed of.

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