Poovachal Rural Housing Co-Operative Society Ltd. Vs JCIT (Kerala High Court)
The Kerala High Court addressed a practical challenge within the income tax Faceless Assessment system, ruling in favor of an assessee who found it impossible to upload thousands of pages of records. The petitioner, Poovachal Rural Housing Co-Operative Society Ltd., an assessee undergoing assessment for the year 2014-2015, was issued a notice by the Joint Commissioner of Income Tax (JCIT) demanding the production of its entire cash book.
The Society approached the High Court seeking a writ of mandamus, arguing that the cash book was so voluminous—running into thousands of pages—that its complete submission through the mandated online mode for the Faceless Assessment Authority was not feasible. The Society sought judicial intervention to command the department not to insist on the impractical online production and to complete the assessment promptly.
In a pivotal moment during the proceedings, the learned Standing Counsel for the Income Tax Department effectively conceded the logistical difficulty. The counsel submitted that uploading the entire document was indeed unnecessary, and proposed that the verification could instead be carried out physically through the local Verification Unit under the Principal Commissioner of Income Tax (VU), Kochi. This concession acknowledged the need for flexibility when dealing with large-scale legacy paper records within the digital assessment regime.
