Supreme Court Slams Income Tax Department for Delay in Filing SLPs
Court says revenue cannot waste judicial time by mistrusting its own lawyers
Ruling highlights need for accountability and efficiency in tax litigation management
By Our Legal Reporter
New Delhi: November 22, 2025:
In a strongly worded order, the Supreme Court of India criticised the Income Tax Department for its repeated delays in filing Special Leave Petitions (SLPs), observing that the department appeared to have “not trusted even upon its lawyers.” The Court expressed displeasure at the revenue’s litigation practices, noting that such delays waste judicial time and undermine the credibility of the department.
The case arose from the Hyderabad Cricket Association (HCA) matter, where the Income Tax Appellate Tribunal (ITAT) had directed fresh verification of charitable expenditure. The Income Tax Department challenged this decision but filed its SLP with undue delay, prompting the Court’s sharp remarks.
Background of the Case
The dispute involved the Hyderabad Cricket Association, which claimed charitable expenditure under the Income Tax Act. The ITAT remanded the matter for fresh verification. Dissatisfied, the Income Tax Department sought to challenge the ITAT’s order before the Supreme Court.
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However, the department delayed filing its SLP, raising questions about its litigation management. The Court noted that the delay was not satisfactorily explained and criticised the department for failing to trust its own legal representatives.
This is not the first time the Supreme Court has expressed frustration with the revenue’s litigation practices. In earlier cases, the Court dismissed SLPs filed with delays of 248 days and even 484 days, remarking that such conduct reflects poor accountability.
Key Observations of the Supreme Court
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- Mistrust of lawyers: The Court remarked that the Income Tax Department seemed to have “not trusted even upon its lawyers,” leading to unnecessary delays.
- Judicial time wasted: The Court emphasised that judicial time is a public resource and cannot be wasted due to departmental inefficiency.
- Need for accountability: The ruling highlighted the importance of proper litigation management within government departments.
- Pattern of delays: The Court noted repeated instances of delayed SLP filings by the revenue, calling for systemic reform.
Why This Matters
This ruling is significant because it addresses systemic issues in tax litigation:
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- Efficiency in justice: Delays in filing appeals slow down resolution of tax disputes.
- Public confidence: Criticism from the Supreme Court damages the credibility of the Income Tax Department.
- Accountability: The ruling underscores the need for better coordination between tax officers and government lawyers.
- Judicial discipline: Reinforces the principle that courts cannot condone unexplained delays.
Impact on Taxpayers
- Faster resolution: If departments improve litigation management, taxpayers will benefit from quicker resolution of disputes.
- Reduced uncertainty: Timely appeals prevent prolonged uncertainty in tax matters.
- Fairness: Ensures that taxpayers are not dragged into endless litigation due to departmental inefficiency.
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Impact on the Income Tax Department
- Need for reform: The department must streamline its litigation processes.
- Trust in lawyers: Greater reliance on legal representatives is essential to avoid delays.
- Systemic accountability: Internal checks must be strengthened to prevent repeated lapses.
Expert Reactions
Legal experts welcomed the Supreme Court’s remarks as a wake up call for the revenue.
- Senior advocates noted that mistrust of lawyers undermines the efficiency of litigation.
- Academics highlighted that government departments must adopt modern litigation management practices.
- Tax professionals said the ruling will encourage accountability and reduce frivolous delays.
Broader Context
The Supreme Court has repeatedly criticised government departments for filing delayed appeals. In tax matters, delays are particularly problematic because they affect revenue collection and taxpayer confidence.
The Court’s remarks in the Hyderabad Cricket Association case align with its broader push for judicial efficiency and accountability in government litigation.
Conclusion
The Supreme Court’s ruling that the Income Tax Department has “not trusted even upon its lawyers” and its criticism of delays in filing SLPs is a landmark in judicial accountability. By highlighting inefficiency and mistrust, the Court has sent a strong message to the revenue to reform its litigation practices.
This verdict strengthens judicial discipline, promotes efficiency, and underscores the principle that justice cannot be delayed due to departmental lapses.
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