Bee Cee Fireworks Industries v. PCIT (2025) 170 taxmann.com 297 / 343 CTR 668 / 247 DTR 500 (Mad)(HC)

S. 143(3) : Assessment-High pitched assessment-Local Committee-Neither a quasi-judicial authority nor a statutory authority-Grievance redressal mechanism only for administrative action-Report not binding on appellate/revisional authorities-Writ petition dismissed.[S. 147, 148, 148A, Art. 226]

The assessee challenged a high-pitched assessment before the Local Committee constituted under CBDT instructions. It was argued that the Committee should grant a hearing before submitting its report. The Court noted that the Local Committee is an internal mechanism created by CBDT  Instruction No. 17/2017, dated 9-11-2015 and Instruction No. 225/101/2021, dated 23-4-2022  to curb arbitrary or high-pitched assessments and to enable the Principal Chief CIT to take administrative action against errant officers. The Committee’s report is not binding on appellate or revisional authorities, and it is discretionary for the Principal Chief CIT to act upon it. Since the Committee is neither a quasi-judicial nor statutory authority, it is not obliged to provide taxpayers with an opportunity of hearing. Thus, the petition was dismissed. (AY 2016-17,  2019-20)

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