Rahul Gupta Vs Income Tax Department (Chhattisgarh High Court)
The Chhattisgarh High Court dismissed a writ appeal challenging the order of the learned Single Judge, who had earlier dismissed the appellant’s writ petition seeking directions against the Income Tax Department and other authorities regarding alleged tax evasion. The writ appeal arose from the order dated 7 January 2026 passed in WPC No. 3084 of 2025.
The appellant had filed the writ petition invoking Articles 14, 19(1)(a), 21, 261, and 265 of the Constitution. The petition sought enforcement of statutory duties in relation to alleged tax evasion based on alleged unaccounted cash transactions of approximately ₹21.80 crore. The appellant relied upon an FIR, sworn testimony before the Family Court, affidavits reflecting disproportionate declared assets, a Tax Evasion Petition (TEP) dated 13 February 2023, supplementary materials, and RTI responses indicating absence of action or inter-agency coordination. According to the appellant, the Income Tax Department rejected the complaint on 22 August 2025 solely on the ground of limitation under Section 148 of the Income-tax Act, 1961, without initiating inquiry under Sections 68, 69, 69A to 69C or exercising investigative powers. The appellant contended that the learned Single Judge failed to distinguish reassessment proceedings from independent investigation or prosecution and ignored the continuing nature of unexplained assets, thereby permitting ongoing violation of tax laws and loss of public revenue.
