The assessee challenged by way of writ petition an intimation under section 143(1) raising demand of approximately Rs. 6,600 crores, contending that such huge demand rendered the statutory remedy of appeal ineffective. Since the impugned intimation was an appealable order under section 246A(1)(a) and there was no requirement of mandatory pre-deposit for admitting and entertaining the appeal, the existence of a substantial demand did not justify exercise of writ jurisdiction by the High Court. The writ petition was therefore not entertained. (AY. 2022-23)
Fiat India Automobiles Ltd. v. DDIT [2025] 170 taxmann.com 789 (Bom.)(HC)
S. 143(1): Assessment-Intimation-Writ petition challenging huge demand-Where intimation was appealable under section 246A and no mandatory pre-deposit was required for filing an appeal, the High Court could not interfere in writ jurisdiction merely because a huge demand was raised. [S. 246A, Art. 226]
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