IN THE HIGH COURT AT CALCUTTA

Constitutional Writ Jurisdiction

(ORIGINAL SIDE)

Present:

The Hon’ble Justice Smita Das De

W.P.O. No. 416 of 2016

M/s. J.M. Global Equities

Vs.

The Deputy Commissioner, Income Tax,

Circle 10 (1) Kolkata

For the Petitioner : Ms. Manju Agarwal

: Mr. S.C. Tiwari

: Ms. Anju Manot

: Ms. Hitoshree Biswas

For the Respondent : Mr. Aryak Dutt

Reserved on : 01.08.2025 Judgment on : 19.08.2025

Smita Das De, J.:-

1. The instant writ Petition arises out of the reassessment proceedings

for the Assessment Year 2010-11 under the provisions of Section 147/143(3) read with section 148 of the Income Tax Act, 1961

(hereinafter referred to as the said Act).

2. Apropo, the facts of the case is that the assessee filed its return of

income to the tune of Rs. 29,56,452/- for the Assessment Year 2010- 11 on September 10, 2010. The case was accordingly processed under Section 143(1) of the said Act. Subsequently the information

was received from the Directorate of Income Tax (Intelligence and Criminal Investigation) Kolkata (herein after referred to as DIT (INV) for the sake of brevity and convenience) about booking loss of Rs. 14,44,92,868/- by the assessee through client code modification. The sai