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The Rajasthan High Court’s Jaipur Bench has disposed of two petitions concerning income-tax settlement applications by following its earlier Friends SPS International India (P) Ltd. ruling. The common order dated 24 September 2025 applies that precedent’s procedural directions; it does not approve either petitioner’s settlement, decide a tax amount, or hold that every application filed by 30 September 2021 was eligible.
What the Rajasthan High Court ordered on 24 September 2025
The order covered D.B. Civil Writ Petition No. 2915/2021, Gopal Goyal v. DCIT, and D.B. Civil Writ Petition No. 10814/2021, filed by Ravi Surya Developers Private Limited and other petitioners. The Jaipur Bench recorded a joint submission from the parties that the legal issue was already settled by a coordinate Bench in Friends SPS International India (P) Ltd. & Ors. v. Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors.
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On that basis, the Bench disposed of both petitions in terms of the earlier decision. It also directed that any pending applications connected with the petitions would stand disposed of. The ruling is therefore a precedent-following disposal rather than a new, independent analysis of each taxpayer’s settlement application.
“Learned counsel appearing for respective parties submit that the issue involved herein is no more res integra and stands resolved by a coordinate Bench of this Court vide order dated 26.03.2025 passed in the case of Friends SPS international India (P) Ltd. & Ors. versus Assistant Commissioner of Income Tax / Deputy Commissioner of Income Tax & Ors.: D.B. Civil Writ Petition No.3372/2021 and other connected matters, and prays for disposal of the instant matters in terms thereof.”
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What happened to the two petitions
Neither petition received a separate merits judgment on the validity of the underlying application. The court did not make a finding that Gopal Goyal, Ravi Surya Developers, or any other named petitioner satisfied all statutory conditions for settlement. Instead, the parties accepted that the coordinate-Bench ruling governed the common issue, so the later Bench adopted that route.
Why the Friends SPS ruling mattered
The earlier decision, dated 26 March 2025, addressed the legal consequences of the change from the former Income-tax Settlement Commission to the Interim Board for Settlement. The Settlement Commission ceased operating on 1 February 2021. The Interim Board was constituted to process applications that remained pending during that transition.
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The dispute also involved a Central Board of Direct Taxes (CBDT) order dated 28 September 2021 issued under section 119(2)(b) of the Income-tax Act, 1961. That order dealt with a limited filing extension and the treatment of qualifying applications during the institutional change.
How the 28 September 2021 CBDT order worked
The order authorized the designated Commissioner to admit applications filed after 31 January 2021 and before 30 September 2021 when the taxpayer met both conditions described in the order:
- The taxpayer had been eligible to apply on 31 January 2021.
- The relevant assessment proceedings were pending when the application was filed.
Applications meeting those requirements were to be treated as “pending applications” for processing by the Interim Board. The CBDT described the extension as relief against genuine hardship, including difficulties associated with the COVID-19 pandemic. The date of 30 September 2021 was therefore part of a specific administrative relief framework; it was not a blanket declaration that every filing made by that date was valid.
Later order compared with Friends SPS
| Issue | 24 September 2025 Gopal Goyal and Ravi Surya Developers order | 26 March 2025 Friends SPS decision |
|---|---|---|
| Cases and date | D.B. Civil Writ Petition Nos. 2915/2021 and 10814/2021; common order of the Rajasthan High Court’s Jaipur Bench on 24 September 2025. | D.B. Civil Writ Petition No. 3372/2021 and connected matters; coordinate-Bench decision on 26 March 2025, neutral citation 2025:RJ-JP:13797-DB. |
| Statutory eligibility analysis | No independent determination of section 245C eligibility or validity of an individual application. | Provided the ruling that the later Bench treated as controlling for the common issue. |
| Role of the CBDT order | Applied the earlier ruling in disputes arising from the 28 September 2021 section 119(2)(b) order. | Addressed the transition framework and the treatment of qualifying late-filed applications. |
| Nature of relief | Procedural disposal in accordance with the coordinate-Bench directions. | Procedural consideration of qualifying applications by the Interim Board, not an automatic final settlement. |
| Questions left open | Whether a particular taxpayer met every statutory requirement, the amount of tax payable, and whether a settlement should ultimately be granted. | Individual application-level questions remained for the competent settlement process. |
What the order did not decide
The wording and disposition impose important limits on what can be claimed from the judgment:
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- It did not grant a settlement to Gopal Goyal, Ravi Surya Developers, or another petitioner.
- It did not calculate, confirm, or reduce any tax, interest, or penalty.
- It did not independently rule that a particular application satisfied section 245C of the Income-tax Act.
- It did not declare that all applications submitted by 30 September 2021 were automatically valid.
- It did not expand the CBDT’s 2021 relief beyond the conditions stated in that order and the directions in the earlier case.
What the decision means for taxpayers with transition-period applications
A taxpayer cannot rely on the 24 September 2025 order alone as proof that an application qualifies. The relevant question remains whether the application falls within the framework recognized in Friends SPS and the CBDT’s 28 September 2021 order.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minute- Identify the filing date. Applications filed after 31 January 2021 had to be filed before 30 September 2021 to come within the extension described by the CBDT.
- Check eligibility as of 31 January 2021. The extension was for taxpayers who were eligible to apply on that date, not for applicants who became eligible later.
- Confirm the assessment status. The relevant assessment proceedings had to be pending when the application was filed.
- Separate admission from settlement. Being treated as a pending application for Interim Board processing is a procedural step. It is not the same as a final settlement order or an acceptance of the tax disclosure.
- Keep the record complete. Filing acknowledgements, assessment-status documents, correspondence with the tax department, and evidence supporting the section 245C conditions may be needed when the competent authority considers the application.
The High Court’s order is significant because it confirms that the coordinate-Bench ruling controls the common legal issue in these petitions. Its practical effect is to channel the matters into the procedural route recognized in Friends SPS, while leaving application-specific eligibility and final settlement questions for the proper forum.
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Key dates
| Date | Event |
|---|---|
| 31 January 2021 | Reference date for determining whether a taxpayer was eligible to apply under the later CBDT relief framework. |
| 1 February 2021 | The former Income-tax Settlement Commission ceased to operate; the Interim Board was created for pending applications. |
| 28 September 2021 | CBDT issued its section 119(2)(b) order authorizing the limited filing extension. |
| 30 September 2021 | End date for the post-31 January applications covered by that extension, subject to the stated conditions. |
| 26 March 2025 | Rajasthan High Court coordinate Bench decided Friends SPS International India and connected matters. |
| 24 September 2025 | Jaipur Bench disposed of the Gopal Goyal and Ravi Surya Developers petitions in accordance with the earlier ruling. |
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