2021 (12) TMI 1220 - SCH - Income Tax

Validity of Section 194A(3)(ixa) - tax deducted at source on the interest payable under an award of the Motor Accident Claims Tribunal ( MACT ) - petitioner had filed a writ petition initially before the High Court of Delhi which was disposed of by granting him liberty to move the Central Board of Direct Taxes ( CBDT ) in a representation - fresh writ petition challenging the decision of the CBDT was dismissed both on the grounds of locus and delay with liberty to file a public interest litigation. HELD THAT - The petitioner is not personally aggrieved by the award of the MACT. A challenge of this nature would have to be brought before the Court by a person aggrieved. We see no reason to entertain a petition which is styled one filed in public interest. In the circumstances this Court is not expressing any opinion on the question of law raised. The petition is dismissed on the grounds which are set out above.

Summary

The Supreme Court dismissed a petition challenging the validity of Section 194A(3)(ixa) of the Income Tax Act 1961 related to tax deduction on interest from a Motor Accident Claims Tribunal award. The petitioner was not personally aggrieved by the award, leading to the dismissal of the petition on the grounds of locus and delay. No opinion was expressed on the raised legal question.