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Jharkhand High Court
The Principal Commissioner Of Income ... vs Tripta Sharma on 11 December, 2025
Author: Sujit Narayan Prasad
Bench: Sujit Narayan Prasad
2025:JHHC:37442-DB
IN THE HIGH COURT OF JHARKHAND AT RANCHI
I.A. No. 13585 of 2024
In/and
Civil Review No. 46 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Tripta Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir Tower,
Main Road, PO & PS- Hindpiri, Ranchi and also at House No. 69,
BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony, PO
- Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh, Pin
Code- 174303. ... ... ... ... Opposite Party
With
I.A. No. 13606 of 2024
In/and
Civil Review No. 47 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Kamal Deo Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir
Tower, Main Road, PO & PS- Hindpiri, Ranchi and also at House No.
69, BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony,
PO - Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh,
Pin Code- 174303. ... ... ... Opposite Party
With
I.A. No. 13582 of 2024
In/and
Civil Review No. 48 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
M/s KDS Contractors Pvt. Ltd. having registered office at Flat No. 3D,
Block 2, 3rd Floor, Space Town Welfare Association, VIP Road,
Teghoria, PO & PS-Kolkata Airport, Kolkata-70052 and also C/o Sri
SK Poddar, Flat No. 501, Mahavbir tower, Main Road, PO-GPO
Kotwali, and PS Kotwali, Ranchi. ... ... Opposite Party
With
Page 1 of 10
2025:JHHC:37442-DB
I.A. No. 13587 of 2024
In/and
Civil Review No. 49 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Tripta Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir Tower,
Main Road, PO & PS- Hindpiri, Ranchi and also at House No. 69,
BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony, PO
- Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh, Pin
Code- 174303. ... ... ... Opposite Party
With
I.A. No. 13578 of 2024
In/and
Civil Review No. 50 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
M/s KDS Contractors Pvt. Ltd. having registered office at Flat No. 3D,
Block 2, 3rd Floor, Space Town Welfare Association, VIP Road,
Teghoria, PO & PS-Kolkata Airport, Kolkata-70052 and also C/o Sri
SK Poddar, Flat No. 501, Mahavbir tower, Main Road, PO-GPO
Kotwali, and PS Kotwali, Ranchi. ... ... Opposite Party
with
I.A. No. 13589 of 2024
In/and
Civil Review No. 51 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Tripta Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir Tower,
Main Road, PO & PS- Hindpiri, Ranchi and also at House No. 69,
BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony, PO
- Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh, Pin
Code- 174303. ... ... ... Opposite Party
With
Page 2 of 10
2025:JHHC:37442-DB
I.A. No. 13612 of 2024
In/and
Civil Review No. 52 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
with
I.A. No. 13614 of 2024
In/and
Civil Review No. 53 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
with
I.A. No. 13605 of 2024
In/and
Civil Review No. 54 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Kamal Deo Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir
Tower, Main Road, PO & PS- Hindpiri, Ranchi and also at House No.
69, BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony,
PO - Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh,
Pin Code- 174303. ... ... ... Opposite Party
With
Page 3 of 10
2025:JHHC:37442-DB
I.A. No. 13576 of 2024
In/and
Civil Review No. 55 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
with
I.A. No. 13615 of 2024
In/and
Civil Review No. 56 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
with
I.A. No. 13609 of 2024
In/and
Civil Review No. 57 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Kamal Deo Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir
Tower, Main Road, PO & PS- Hindpiri, Ranchi and also at House No.
69, BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony,
PO - Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh,
Pin Code- 174303. ... ... ... Opposite Party
With
Page 4 of 10
2025:JHHC:37442-DB
I.A. No. 13579 of 2024
In/and
Civil Review No. 58 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
M/s KDS Contractors Pvt. Ltd. having registered office at Flat No. 3D,
Block 2, 3rd Floor, Space Town Welfare Association, VIP Road,
Teghoria, PO & PS-Kolkata Airport, Kolkata-70052 and also C/o Sri
SK Poddar, Flat No. 501, Mahavbir tower, Main Road, PO-GPO
Kotwali, and PS Kotwali, Ranchi. ... ... Opposite Party
with
I.A. No. 13611 of 2024
In/and
Civil Review No. 59 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
with
I.A. No. 13570 of 2024
In/and
Civil Review No. 60 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
With
Page 5 of 10
2025:JHHC:37442-DB
I.A. No. 13577 of 2024
In/and
Civil Review No. 61 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Rajat Minerals Pvt. Ltd., having registered office at Flat No. 3D, Block
2, 3rd Floor, Space Town Welfare Association, VIP Road, Teghoria,
P.O. & P.S. Kolkata Airport, Kolkata-700052 and also at C/O Sri S.K.
Poddar, Flat NO. 501, Mahabir Tower, Main Road, P.O. GPO Kotwali,
and P.S. - Kotwali, Ranchi. ... ... ... Opposite Party
With
I.A. No. 13607 of 2024
In/and
Civil Review No. 62 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Kamal Deo Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir
Tower, Main Road, PO & PS- Hindpiri, Ranchi and also at House No.
69, BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony,
PO - Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh,
Pin Code- 174303. ... ... ... Opposite Party
With
I.A. No. 13580 of 2024
In/and
Civil Review No. 63 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
M/s KDS Contractors Pvt. Ltd. having registered office at Flat No. 3D,
Block 2, 3rd Floor, Space Town Welfare Association, VIP Road,
Teghoria, PO & PS-Kolkata Airport, Kolkata-70052 and also C/o Sri
SK Poddar, Flat No. 501, Mahavbir tower, Main Road, PO-GPO
Kotwali, and PS Kotwali, Ranchi. ... ... Opposite Party
With
Page 6 of 10
2025:JHHC:37442-DB
I.A. No. 13588 of 2024
In/and
Civil Review No. 64 of 2025
The Principal Commissioner of Income Tax, Central, Patna having its
office at Central Revenue Building, 3rd Floor, Birchand Patel Marg,
PO-C.R. Building & PS- Patna, District- Patna. ... Petitioner
Versus
Tripta Sharma, C/o Shri S.K. Poddar, Flat No. 501, Mahabir Tower,
Main Road, PO & PS- Hindpiri, Ranchi and also at House No. 69,
BVO, Bharolian Khurd, Nangal Road, Opposite Professor Colony, PO
- Una H.O. & P.S.- PP City, Una, District-Una, Himachal Pradesh, Pin
Code- 174303. ... ... ... Opposite Party
---------
CORAM: HON'BLE THE CHIEF JUSTICE
HON'BLE MR. JUSTICE SUJIT NARAYAN PRASAD
---------
For the Appellant : Mr. Anurag Vijay, Sr.S.C.
For the Respondents: Mrs. Darshana Poddar Mishra, Advocate
---------
02/Dated: 11.12.2025
I.A. No. 13585 of 2024 in Civil Review No. 46 of 2025, I.A. No.
13606 of 2024 in Civil Review No. 47 of 2025, I.A. No. 13582 of
2024 in Civil Review No. 48 of 2025, I.A. No. 13587 of 2024 in Civil
Review No. 49 of 2025, I.A. No. 13578 of 2024 in Civil Review No.
50 of 2025, I.A. No. 13589 of 2024 in Civil Review No. 51 of 2025,
I.A. No. 13612 of 2024 in Civil Review No. 52 of 2025, I.A. No.
13614 of 2024 in Civil Review No. 53 of 2025, I.A. No. 13605 of
2024 in Civil Review No. 54 of 2025, I.A. No. 13576 of 2024 in Civil
Review No. 55 of 2025, I.A. No. 13615 of 2024 in Civil Review No.
56 of 2025, I.A. No. 13609 of 2024 in Civil Review No. 57 of 2025,
I.A. No. 13579 of 2024 in Civil Review No. 58 of 2025, I.A. No.
13611 of 2024 in Civil Review No. 59 of 2025, I.A. No. 13570 of
2024 in Civil Review No. 60 of 2025, I.A. No. 13577 of 2024 in Civil
2025:JHHC:37442-DB
Review No. 61 of 2025, I.A. No. 13607 of 2024 in Civil Review No.
62 of 2025, I.A. No. 13580 of 2024 in Civil Review No. 63 of 2025
I.A. No. 13588 of 2024 in Civil Review No. 64 of 2025
1) Even though all these interlocutory applications have been
vehemently opposed, however, for the reasons set out in the
applications, we find sufficient cause to condone the delay that
has crept up in filing the civil review petitions.
2) Ordered accordingly.
3) All the Interlocutory applications filed in respective civil review
petitions shall stand disposed of.
Civil Review Nos. 46 of 2025 ,Civil Review No. 47 of 2025, Civil
Review No. 48 of 2025, Civil Review No. 49 of 2025, Civil Review
No. 50 of 2025, Civil Review No. 51 of 2025, Civil Review No. 52 of
2025, Civil Review No. 53 of 2025, Civil Review No. 54 of 2025,
Civil Review No. 55 of 2025, Civil Review No. 56 of 2025, Civil
Review No. 57 of 2025, Civil Review No. 58 of 2025, Civil Review
No. 59 of 2025, Civil Review No. 60 of 2025, Civil Review No. 61 of
2025, Civil Review No. 62 of 2025, Civil Review No. 63 of 2025 and
4) Since the common questions of law and fact arise in all these
review petitions, therefore, they are taken up together for
consideration and are being disposed of by a common
judgment.
5) These civil review petitions are directed against the judgment
passed by this Court on 09.07.2024 whereby the Tax Appeals
bearing Tax Appeal Nos. 14 of 2020, 11 of 2020, 12 of 2020, 13
of 2020, 15 of 2020, 16 of 2020, 17 of 2020, 18 of 2020, 19 of
2020, 20 of 2020, 21 of 2020, 22 of 2020, 23 of 2020,
2025:JHHC:37442-DB
24 of 2020, 25 of 2020, 26 of 2020, 27 of 2020, 28 of 2020 and
29 of 2020 were ordered to be dismissed on the ground of
limitation.
6) It is not in dispute that the majority of appeals so filed during
the covid-period on different dates but post March, 2020 that is
during the covid-period. Like for example Tax Appeal No. 14 of
2020 was filed on 12.06.2020 and, therefore, in terms of the
judgment passed by the Hon'ble Supreme Court in case title
Suo Motu Writ Petition (C) No. 3 of 2020 decided along with
miscellaneous petitions on 10.01.2022, the period from
15.03.2020 till 28.02.2022 was required to be excluded for the
purpose of limitation as may be prescribed under any general or
special law in respect of all judicial or quasi judicial proceedings
as is evident from paragraph 5 (I) of the order which reads as
under:-
"I. The order dated 23.03.2020 is restored and in
continuation of the subsequent orders dated 08.03.2021,
27.04.2021 and 23.09.2021, it is directed that the period
from 15.03.2020 till 28.02.2022 shall stand excluded for
the purposes of limitation as may be prescribed under
any general or special laws in respect of all judicial or
quasi judicial proceedings."
7) In view of the aforesaid directions, the Court has no hesitation
to conclude that there is error apparent on the face of the record
whereby all the tax appeals under review were ordered to be
dismissed.
2025:JHHC:37442-DB
8) Accordingly, all the civil review petitions are allowed.
9) The tax appeals shall stand restored to its original number and
all the applications filed for condonation of delay shall be
deemed to be allowed.
10) List all the tax appeals before the appropriate Bench having the
jurisdiction, as the tax appeals shall be deemed to have been
filed within time in terms of the order passed by the Hon'ble
Supreme Court.
11) The limitation petitions are disposed of as the appeals would be
deemed to have been filed within time.
(Tarlok Singh Chauhan, C.J.)
NAFR
11/12/2025
Sharda/MM
Cp.02 (Sujit Narayan Prasad, J.)
Uploaded on. 12/12/2025
