Pricewaterhouse Coopers Private Limited Vs ACIT (Calcutta High Court)
The Calcutta High Court allowed a writ petition challenging an assessment order dated March 30, 2026 passed under Section 143(3) of the Income Tax Act, 1961 for Assessment Year 2024-25, along with the consequential demand and penalty proceedings, on the ground that the assessment was completed in violation of the principles of natural justice and without providing an effective opportunity of hearing.
The petitioner, a consultancy company, filed its return of income declaring a loss, which was later revised. The return was initially processed under Section 143(1), resulting in a refund. Subsequently, the case was selected for scrutiny through the National Faceless Assessment Centre (NFAC), which issued notices under Sections 143(2) and 142(1). The petitioner responded to all such notices by furnishing the required information and supporting documents. Later, the assessment proceedings were transferred to the Jurisdictional Assessing Officer (JAO), who also issued multiple notices under Section 142(1), to which the petitioner submitted replies.
On March 28, 2026, the JAO issued a show cause notice stating that information had been received from the office of the DCIT, Central Circle-3, Hyderabad regarding the petitioner’s alleged involvement in the acquisition of KSK Energy Ventures Ltd. through consultancy or advisory services. The petitioner was asked to explain its role, if any, and submit supporting documents by March 30, 2026. The petitioner filed its reply on the stipulated date. However, on the very same day, the Assessing Officer passed the assessment order raising a tax demand of Rs. 87.20 crore without granting any further opportunity of hearing.
