Bankura District Central Co-operative Bank Limited Vs Union of India & Ors. (Calcutta High Court)
The writ petition before the Calcutta High Court challenged an order dated 25 June 2025 passed under section 148A(3) of the Income-tax Act, 1961, and the consequential notice issued under section 148, initiating reassessment proceedings for assessment year 2019–20. The petitioner, a co-operative society engaged in banking business, had originally operated under one Permanent Account Number (PAN) and later obtained a new PAN, under which it thereafter conducted its transactions and filed its income-tax returns. According to the petitioner, all banks were informed of the change, though one bank updated the new PAN belatedly.
The petitioner highlighted that similar reassessment proceedings for assessment year 2020–21 had earlier been initiated by referring to the old PAN, during which the petitioner explained the PAN change and asserted that all transactions, including those reflected under the old PAN, were duly accounted for in returns filed under the new PAN. In that assessment, although significant amounts relating to term deposits and cash transactions through a particular bank were referred to in the show-cause notice, no additions were ultimately made, which according to the petitioner amounted to acceptance of its explanation by the Assessing Officer.
