Repeated representations cannot revive a stale cause of action or extend limitation.

The applicant, a retired Assistant Commissioner of Income Tax, sought directions for payment of rewards in respect of 43 income-tax assessment cases under the Government’s 1985 Reward Scheme for uncovering tax evasion, detecting tax avoidance, and improving the quality of assessment work.

The respondents examined the claims and communicated that the applicant was ineligible in most cases; in the remaining cases, requisite reports were incomplete or records were unavailable.

The authorities issued communications dated 10 June 2014 and 16 December 2014 rejecting or otherwise disposing of the claims, and subsequently prepared further review reports dated 26 November 2015 and 30 June 2016.

Despite the earlier rejection, the applicant submitted another representation dated 19 October 2016 and filed the present Original Application in January 2017.

1. Whether the applicant was entitled to rewards in respect of the 43 assessment cases under the 1985 Reward Scheme.

2. Whether the Original Application was barred by limitation, and whether repeated representations could revive or extend a stale cause of action.

The Tribunal applied the Government of India’s Reward Scheme introduced through the CBDT D.O. dated 6 November 1985, under which rewards were payable only where the prescribed conditions were satisfied.

It held that repeated non-statutory representations do not revive or indefinitely postpone limitation, relying on State of Tripura v. Arabinda Chakraborty, 2014 (6) SCC 460.

It further relied on Union of India v. M.K. Sarkar, 2010 (2) SCC 59, which requires a court or tribunal to determine whether a claim concerns a live issue or a dead and stale dispute before directing consideration of a representation; a stale claim should not be revived merely by seeking its reconsideration.

The Tribunal found that the respondents had substantively considered the applicant’s claims rather than leaving them undecided.

The assessment of the 43 cases showed that the applicant was ineligible in most matters, while the remaining cases lacked complete reports or available records.

Subsequent departmental reports also found the claims untenable or liable to rejection.

Since the rejection and related communications had been conveyed to the applicant in 2014, his later representation dated 19 October 2016 could not revive the cause of action or extend limitation.

Applying the principles in Arabinda Chakraborty and M.K. Sarkar, the Tribunal concluded that the claim was both stale and without merit under the Reward Scheme.

It held that the applicant’s reward claims had been duly examined and rejected because they did not satisfy the prescribed conditions of the 1985 Reward Scheme, and that the Original Application was additionally barred by limitation.

The Original Application was accordingly dismissed on the grounds of limitation and merits, with no order as to costs.