IN THE HIGH COURT AT CALCUTTA Constitutional Writ Jurisdiction Appellate Side Ct.551 23.12.25 Item No.07 Sws.M WPA 10211 of 2025 Little More Engineering Private Limited Vs Union of India & Ors.

Mr. Avra Mazumder Ms. Alisha Das Ms. Elina Dey Ms. Maitreyee Naskar …for the petitioner Mr. Soumen Bhattacharjee Mr. Ankan Das Ms. Shradhya Ghosh …for the Income Tax Authority

1. This writ petition assails the action of the respondent/revenue authorities in adjusting the amounts refundable to the petitioner in respect of the assessment year 2024-25 with outstanding demand pertaining to the assessment year 2013-14.

2. An assessment order dated March 11, 2016 under Section 143(3) of the Income Tax Act, 1961 for the assessment year 2013-14 had been passed against the petitioner. The petitioner carried the said assessment order in appeal before the Commissioner of Income Tax (Appeals). During pendency of the appeal, the petitioner made an application under Section 220(6) of the Income Tax Act, 1961, before the Assessing Officer and deposited a sum in excess of 20% of the tax in dispute. The Assessing Officer, upon considering the petitioner’s application under Section

220(6) of the said Act of 2016