PCIT Vs Eastern Coalfields Ltd. (Calcutta High Court)
In the case of PCIT vs Eastern Coalfields Ltd., the Calcutta High Court upheld the Income Tax Appellate Tribunal’s (ITAT) decision, which quashed the order passed under Section 263 of the Income Tax Act, 1961. The case revolved around the alleged erroneous assessment of Minimum Alternate Tax (MAT) credit and provisions for doubtful debts for the assessment year 2016-17. The Principal Commissioner of Income Tax (PCIT) had argued that the assessment order was erroneous and prejudicial to the revenue’s interests, claiming improper verification of MAT credit and inadequate disallowance of doubtful debts provisions. However, the ITAT found that the assessment order passed under Section 143(3) was neither erroneous nor prejudicial to the revenue. The High Court concurred with the ITAT’s findings, noting that the issues surrounding MAT credit were still pending in appeal and had not yet attained finality, allowing for corrections under Section 115JAA(6) if necessary. Additionally, the court observed that the PCIT’s assertion of the assessee’s non-response to the show cause notice was factually incorrect. Therefore, the court dismissed the revenue’s appeal, finding no substantial question of law in the matter, and upheld the ITAT’s decision.
FULL TEXT OF THE JUDGMENT/ORDER OF CALCUTTA HIGH COURT
