Sanctum Wealth Private Limited vs National Faceless Assessment Centre New Delhi Through Pccit And Ors. — Bombay HC (2025) — LawSathi Research

Sanctum Wealth Private Limited vs National Faceless Assessment Centre New Delhi Through Pccit And Ors. — Bombay HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

Impugned Assessment Order, Computation Sheet and Demand Notice dated 21st March 2025 and all consequential notices set aside; matter remanded to the Faceless Assessing Officer for fresh consideration, with a personal hearing to the Petitioner before a detailed reasoned Assessment Order; no order as to costs.

Issue for consideration

Whether the impugned assessment order (with the Computation Sheet and Demand Notice dated 21st March 2025) was liable to be quashed on the ground that it was passed in breach of the principles of natural justice.

Court's answer

The Court set aside the impugned Assessment Order dated 21st March 2025, the impugned Computation Sheet dated 21st March 2025 and the impugned Demand Notice dated 21st March 2025, along with all other consequential notices arising therefrom.

Ratio / Principle

The matter was remanded back to the Faceless Assessing Officer (Respondent No.1) for fresh consideration.

Key takeaways

The Assessing Officer shall give a personal hearing to the Petitioner and only thereafter pass a detailed reasoned Assessment Order.ratio¶18
On the Petitioner's submission that, the documents being voluminous, the matter be decided by the Jurisdictional Assessing Officer (Respondent No.2), the Court expressly did not opine, leaving the Petitioner free to make the request before the appropriate authority, who shall take a call on it.obiter¶19

Detailed headnote1 paragraphs

Writ Petition No. 2288 of 2025 - Sanctum Wealth Pvt. Ltd. v. National Faceless Assessment Central, New Delhi & Others (High Court of Bombay, Ordinary Original Civil Jurisdiction; Coram: B. P. Colabawalla & Firdosh P. Pooniwalla, JJ.; 22 July 2025): The petition sought quashing of the assessment order, Computation Sheet and Demand Notice, all dated 21st March 2025, on the short ground that the assessment order was passed in breach of the principles of natural justice. After partial arguments, the Revenue's learned counsel, on instructions, stated that the impugned Assessment Order could be set aside and the matter remanded to the Faceless Assessing Officer (Respondent No.1) for fresh consideration. Acting on those instructions, the Court set aside the impugned Assessment Order, Computation Sheet and Demand Notice and all consequential notices arising therefrom, and remanded the matter to the Faceless Assessing Officer for fresh consideration, directing that the Assessing Officer give the Petitioner a personal hearing and only thereafter pass a detailed reasoned Assessment Order. The Court declined to opine on the Petitioner's request that the matter, involving voluminous documents, be decided by the Jurisdictional Assessing Officer (Respondent No.2), leaving the Petitioner free to make the request before the appropriate authority. The Writ Petition was disposed of in these terms with no order as to costs.

124-wp-2288-2025.doc

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION

WRIT PETITION NO.2288 OF 2025

Sanctum Wealth Pvt. Ltd., .. Petitioner.

Versus

National Faceless Assessment Central, New Delhi & Others .. Respondents

Digitally signed by SMITA SMITA RAJNIKANT RAJNIKANT JOSHI JOSHI Date:2025.07.24 10:17:19 +0530

Adv. Nishant Thakkar with Adv. Jasmin Amalsadvala i/b. Lumiere Law Partners, for the Petitioner.

Adv. Shilpa Goel , for the Respondents.

CORAM: B. P. COLABAWALLA & FIRDOSH P. POONIWALLA, JJ. DATE: JULY 22, 2025

P. C.

1 The above Writ Petition is filed seeking to quash the impugned assessment order dated 21^st March,2025, the impugned Computation Sheet dated 21^st March, 2025 and the impugned Demand Notice also dated 21^st March, 2025.

2 The short ground on which the above order and the notices are challenged is that the impugned assessment order has been passed in breach of the principles of natural justice.

S.R.JOSHI

124-wp-2288-2025.doc

3 After the matter was argued for some time, Ms. Goel, the learned Advocate appearing on behalf of the Revenue, on taking instructions, stated that to put an end to the controversy, the impugned Assessment Order can be set aside and the matter can be remanded back to the Faceless Assessing Officer (Respondent No.1) for fresh consideration.

4 In light of the aforesaid instructions, we hereby set aside the impugned Assessment Order dated 21^st March, 2025, the impugned Computation Sheet dated 21^st March, 2025 as well as the impugned Demand Notice dated 21^st March, 2025 and all other consequential notices arising there from, and remand the matter back to the Faceless Assessing Officer for fresh consideration.

5 The Assessing Officer shall give a personal hearing to the Petitioner and only thereafter pass a detailed reasoned Assessment Order.

6 At this stage, the learned Advocate appearing on behalf of the Petitioner submitted that since the documents are voluminous, it would be better if the matter is decided by the Jurisdictional Assessing Officer (Respondent No.2). If this is the case, the Petitioner is free to make this request before the appropriate authority, who shall then take a call on such request. We have not opined one way or the other on this aspect.

Page 2 of 3 JULY 22, 2025

S.R.JOSHI

124-wp-2288-2025.doc

7 The Writ Petition is disposed of in the aforesaid terms. However,

there shall be no order as to costs.

8 This order will be digitally signed by the Private Secretary/ Personal Assistant of this Court. All concerned will act on production by fax or email of a digitally signed copy of this order.

[FIRDOSH P. POONIWALLA, J.]

Page 3 of 3 JULY 22, 2025

S.R.JOSHI