OD-1

ORDER SHEET WPO/901/2025

IN THE HIGH COURT AT CALCUTTA

CONSTITUTIONAL WRIT JURISDICTION

ORIGINAL SIDE

MCPI PRIVATE LIMITED

VS.

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA &

ORS.

BEFORE:

The Hon’ble JUSTICE OM NARAYAN RAI

Date: 6th January, 2026.

Mr. J. P. Khaitan, Sr. Adv., Mr. Pratyush Jhunjhunwala, Ms. Akshara

Shukla, Mr. Aritra Nag, Advocates for the petitioner.

Mr. Prabir Kumar Bhowmick, Ms. Aishwarya Rajyashree, Mr. Vivek

Gupta, Advocates for the respondent/revenue authorities.

The Court : Affidavit of service filed today be kept with the records.

This writ petition assails a notice issued under Section 148 of the

Income Tax Act, 1961 whereby proceedings for reassessment of the

petitioner’s income for the assessment year 2020-21 have been initiated.

Mr. Khaitan, learned Senior Advocate appearing for the petitioner

submits that the notice impugned has been issued without the Assessing Officer having in its possession information suggesting escapement of income in terms of Section 148 of the said Act of 1961. It is submitted that in such view of the matter, the notice is wholly without jurisdiction. It is further submitted that upon receipt of the said notice, the petitioner wro