IN THE HIGH COURT AT CALCUTTA Constitutional Writ Jurisdiction Appellate Side Ct.551 20.01.2026 Item No.22 Sws.M WPA 22044 of 2025 Bankura District Central Co-operative Bank Limited Vs Union of India & Ors.

Mr. Avra Mazumder Ms. Alisha Das Ms. Rupomita Ghosh …for the petitioner Mr. Prithu Dudhoria Mr. Madhu Jana …for the Income Tax Department

1. Supplementary Affidavit filed in Court today is taken on record.

2. This writ petition is directed against an order dated June 25, 2025 passed under Section 148(A)(3) of the Income Tax Act, 1961 as well as the consequential notice dated June 25, 2025 issued under Section 148 of the Said Act of 1961 thereby initiating proceedings for reassessment of the petitioner’s income for the assessment year

2019-20.

3. The case of the petitioner is that it is a Co-

operative Society carrying on banking business was initially operating under Permanent Account No. (PAN) - AAGFB4500N. Subsequently, the petitioner applied for and was issued a new PAN being AABAB6253G. After obtaining the new PAN, the petitioner has been conducting its transactions under the new PAN itself. It is the petitioner’s case that the petitioner has informed its respective bankers about the fact that the petitioner has obtained a new PAN but while all the other banks had updated the petitioner’s new PAN in the Bank’s database pertaining to the petitioner, only IDBI Bank updated the same belatedly. A supplementary affidavit has been filed in Court bringing on record a letter dated March 17, 2025 to prop the contention that IDBI updated the new PAN of the petitioner in respect of petitioner’s accounts with the said Bank belatedly.

4. It is the petitioner’s further case that earlier too, proceedings for reassessment of the petitioner’s income for the assessment year 2020-2021 had been initiated against the petitioner by referring to the old PAN, i.e., AAGFB4500N. The petitioner participated in the said proceedings and brought it to the knowledge of the Assessing Officer that the PAN of the petitioner had been changed and that for the purpose of filing its returns, the petitioner had been using the new PAN, i.e., AABAB6253G.

5. It is the petitioner’s case that although the notice to show-cause that had been issued to the petitioner (in a bid to reopen the petitioner’s case for assessment of the petitioner’s income) for assessment year 2020-21 indicated a sum of Rs.1,25,06,44,974/- insofar as the transaction related to purchase of term deposits through IDBI Bank is concerned and Rs.27,13,80,000/- insofar as cash deposits or cash withdrawals through IDBI Bank is concerned, yet, in the assessment order, no addition on the said two grounds were made. It is, therefore, the petitioner’s contention that the petitioner’s version that all the transactions of the petitioner including those that were reflected under the old PAN were accounted for in the income tax return filed under the new PAN, was accepted by the Assessing Officer.

6. Subsequently, another notice dated March 31, 2025 under Section 148A(1) of the said Act of 1961 was issued to the petitioner asking the petitioner to show-cause as to why the petitioner’s income for the assessment year 2019-20 shall not be reassessed. The petitioner replied thereto on April 15, 2025 and indicated to the Assessing Officer that the petitioner was ready to provide any further detail that may be required by the Assessing Officer. Thereafter, on May 8, 2025 the petitioner furnished answers to queries raised by the respondents/revenue authorities and once again stressed that the petitioner would provide further details, if required.

7. Ultimately, on June 25, 2025, the Assessing Officer passed the order impugned under Section 148 A (3) of the said Act of 1961 thereby observing that the petitioner had not filed its return for the assessment year 2019-20 and that the petitioner had not produced the balance-sheet and the profit and loss account for the purpose of reconciliation of the petitioner’s claim. A no