ALLAHABAD HIGH COURT · SOURCE-REVIEWED PROCEDURAL ORDER
Subodh Chandra Seth v. Income Tax Officer and Four Others
Writ Tax No.75 of 2022 ·
Supplied court order; no reported citation stated
Writ dismissed after the petitioner sought to participate in reassessment; investigation information described only prima facie.
Division Bench · Surya Prakash Kesarwani · Jayant Banerji
1. Facts of the case
Subodh Chandra Seth challenged Revenue action in WritTax 75/2022. Revenue produced information received by the Assessing Authority through an email dated 13 July 2019 from DDIT(Investigation), UnitA-2,Mumbai, concerning sales of M/s TilakVentureLtd. stock of Rs.1,06,13,822 during FY 2014-15, relating to AY 2015-16.
2. Discussion by the Hon’ble Court
The Court described the information as prima facie indicating involvement in penny stocks. The material was returned in Court to Revenue counsel for return to the authority. The description is not a final factual determination of bogus gains or an adjudication of tax liability.
3. Judicial decision
After petitioner's counsel stated that he wished to participate in reassessment and requested withdrawal, the operative paragraph dismissed the writ and stated that the petitioner may participate in reassessment as stated.
4. Outcome / in whose favour
The writ ended and reassessment participation remained available. The order does not decide ultimate tax merits, quantify taxable gains, validate every jurisdictional step or record a final fraud finding.
5. AKHB REVIEW POINT
Keep Revenue information and the Court's prima facie description separate from established facts. The source requests dismissal as withdrawn, but the operative sentence simply says dismissed; preserve that wording rather than add a merits ground or an unstated statutory ruling. FY/AY and amount are express; PAN is not.
Source and verification
Complete supplied one-page original read and visually inspected; original PDF bytes verified by SHA-256. Only source-identified provisions and assessment years are recorded. No PAN is stated. Subsequent treatment and current law have not been cleared.
Source SHA-256: 2515f47f8b23f50dbb6fb7ddef48a96ccaf4584bedf295f657e8e15cf4459d2e
Only source-identified provisions are recorded. No current monetary threshold, current statutory equivalence or 2025 Act applicability is inferred.
Source checked 2026-10-19. Subsequent proceedings and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court’s holding. No current-law clearance is claimed.