Writ petition against an income tax reassessment-related assignment order under Sections 147, 144B and 144. Since the order was appealable, the court relegated the petitioner to the appellate authority with limitation relief, liberty to submit additional materials, and a stay on penalty proceedings.
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W.P(MD)No.25604 of 2025
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED : 18.09.2025
CORAM
THE HONOURABLE MR.JUSTICE G.R.SWAMINATHAN
W.P(MD)No.25604 of 2025 and W.M.P(MD)Nos.20046 & 20048 of 2025
Selvam
... Petitioner
Vs.
1.The Commissioner of
Income Tax, Office of the Commissioner of Income Tax,
Karur District.
2.The Deputy Commissioner of Income Tax, Office of the Deputy Commissioner of Income Tax, Karur District. ... Respondents
Prayer : Writ Petition filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of Certiorarified Mandamus, to call for the records pertaining to the impugned order in DIN - ITBA/AST/S/147/2024-25/1073880277(1), dated 01.03.2025, passed by the second respondent and QUASH the same as void and illegal and
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W.P(MD)No.25604 of 2025
consequently directing the second respondent not to impose Penalty and Interest on the basis of the documents submitted by the petitioner along with material evidences available.
For Petitioner : Mr.B.Char Murugan For Respondents : Mr.N.Dilipkumar
ORDER
Heard both sides.
2.The petitioner has suffered the impugned assignment order
passed under Section 147 read with 144B and 144 of the Income Tax Act. The order is appealable.
3.I therefore relegate the petitioner to go before the appellate
authority. The petitioner undertakes to file an appeal before the appellate authority within a period of four weeks from the date of receipt of a copy of this order. On such filing, it shall be entertained without reference to limitation and dispose of on merits and in accordance with law. All the contentions of the petitioner are left open. The petitioner states that if only the additional materials now available with him are perused, the
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W.P(MD)No.25604 of 2025
Consequently, connected miscellaneous petitions are closed.
18.09.2025
NCC : Yes / No Index : Yes / No Internet : Yes / No MGA
To
Karur District.
Office of the Deputy Commissioner of Income Tax,
Karur District.
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W.P(MD)No.25604 of 2025
G.R.SWAMINATHAN, J.
MGA
W.P(MD)No.25604 of 2025
18.09.2025
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1 issue framed by the court
Whether a writ petition lies against an assessment assignment order under Sections 147/144B/144 when the order is appealable.
2 provisions across 2 enactments
Selvam
The Commissioner of Income Tax, Karur District
The Deputy Commissioner of Income Tax, Karur District
G.R.Swaminathan
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
