High Court of Judicature at Madras · Judgments and reasoned final orders

NN 605 Idaikkattur PACCS (Rep. by Secretary P. Ramaraja) v. The Income Tax Officer, Assessment Unit, New Delhi

W.P.(MD) No. 31503 of 2025 ·

Primary Agricultural Co-operative Credit Society (PACCS) ex parte reassessment under sections 147, 144 and 144B: following batch order in N.N.625 V. Pudur PACCS dated 11.07.2024, impugned order dated 11.02.2025 quashed and remanded for fresh consideration on merits.

1. FACTS OF THE CASE

The petitioner, a Primary Agricultural Co-operative Credit Society (NN 605 Idaikkattur PACCS), failed to file its regular return under section 139(4) and suffered an ex parte reassessment order dated 11.02.2025 under section 147 read with sections 144 and 144B.

Source: Paragraphs 1-2; PDF p. 2

2. DISCUSSION BY THE COURT

Noting that in a batch of writ petitions involving identically situated Primary Agricultural Co-operative Credit Societies (N.N.625 V. Pudur Primary Agricultural Co-operative Credit Society v. The Assessment Unit, order dated 11.07.2024), the Court had set aside the ex parte assessment orders and remitted the matters for fresh consideration, the Single Judge applied the same course.

Source: Paragraphs 3-5; PDF pp. 2-3

3. JUDICIAL DECISION

Quashed the impugned assessment order dated 11.02.2025 and remitted the matter to the respondent Assessment Unit for fresh consideration on merits.

Source: Paragraphs 5-6; PDF p. 3

4. OUTCOME

Assessee - Impugned assessment order dated 11.02.2025 quashed and matter remitted to the Assessment Unit for fresh consideration on merits.

Source: Paragraphs 5-6; PDF p. 3

5. AKHB REVIEW POINT

AKHB analysis: rural Primary Agricultural Co-operative Credit Societies facing ex parte section 144/147 assessments due to non-filing of returns under section 139 can rely on the Madurai Bench PACCS batch orders to obtain a merits remand.

Source: AKHB analysis based on Paragraphs 3-5; PDF pp. 2-3

Source and verification

4-page official High Court of Judicature at Madras judgment PDF (20251106_HCMD011495552025.pdf).

Original PDF: 4 pages · SHA-256: 95b856b41349dd9522b7d48b48f95c7979ed89daecea02243b8ccdedd1bf815f

Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.

Applies sections 139(4), 144, 144B and 147 of the Income-tax Act, 1961. Income-tax Act, 2025 equivalence is not verified.

Full primary judgment PDF read page-by-page and verified against the AKHB Google Drive repository. Comprehensive subsequent judicial treatment has not been independently verified.

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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.