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2026 Supreme(Online)(Mad) 36138
IN THE HIGH COURT OF JUDICATURE AT MADRAS
C. SARAVANAN, J
M/s.Smrithi Rekha Foundation – Appellant
Versus
The Centralised Processing Centre, Income Tax Department, Bengaluru – Respondent
WMP Nos.14275 & 14276 of 2026 | Writ Petition
For the Appellants/Petitioners: Mr.R.Lakshmi Ratan
For the Respondents: Mr.V.J.Arul Raj, Senior Standing Counsel
Premature processing of income tax return before response deadline violates natural justice principles.
Headnote:The petitioner challenged the intimation under Section 143(1) of the Income Tax Act, 1961, dated 22.12.2025, for assessment year 2024-25, and the rectification order under Section 154 dated 14.01.2026. The return was filed on 09.10.2024 and information was sought on 09.12.2025, but processed prematurely on 22.12.2025 before the 30-day response period expired. The rectification application was rejected without hearing. The Court found violation of natural justice principles due to hasty processing before the response deadline and absence of hearing. Issues framed included legality of premature processing under Section 143(1) and rejection of rectification under Section 154 without opportunity. The Court held that processing prior to the stipulated response time infringes natural justice, requiring fresh processing after affording opportunity. The impugned orders were quashed, and the matter remitted for fresh processing with directions to furnish information within 30 days, excluding the period for limitation purposes.
| Table of Content |
|---|
| 1. challenge to premature return processing under section 143(1). (Para 2 , 3) |
| 2. rectification under section 154 rejected without hearing. (Para 4) |
| 3. hasty processing violates natural justice principles. (Para 6) |
| 4. remand for fresh processing with time-bound directions. (Para 7 , 8) |
ORDER
Mr.V.J.Arul Raj, Senior Standing Counsel takes notice for the respondents.
2.This Writ Petition is being disposed of at the stage of admission itself with the consent of the learned counsel for the petitioner and the learned Senior Standing Counsel for the respondents.
3.The petitioner is before this Court against the impugned processing of return under Section 143(1) of the Income Tax Act, 1961, dated 22.12.2025, for the assessment year 2024-25. The impugned order processed the Return of Income which was filed by the petitioner on 09.10.2024. It is noticed that the petitioner was called upon to furnish certain information on 09.12.2025, within a period of 30 days. The said period expired on 08.01.2026. Even before that, the Return that was filed earlier, was processed on 22.12.2025
4.In this background, the petitioner filed an application under Section 154 of the Act, which stood rejected on 14.01.2026, without hearing the petitioner. The deadline for completing the assessment under Section 153 of the Act would have been 31.03.2026
5.Under these circumstances, the Return of Income that was processed on
22.12.2025 under Section 143(1) of the Act was sought to be rectified by the petitioner by filing an application for rectification under Section 154 of the Act, which also stands rejected on 14.01.2026.
6.Clearly, the processing of Returns filed earlier was done in a hurry and has resulted in violation of principles of natural justice, particularly, even before the timeline prescribed for filing the information called for could be responded, the return was processed on 22.12.2025. Considering the same, the impugned orders are quashed and the case is remitted back to the 2nd respondent to process the Return of Income afresh or to pass a fresh order in accordance with law.
7.Needless to state, the information that was called for from the petitioner on 09.12.2025 shall be furnished by the petitioner before the 2nd respondent, within a period of 30 days from today. The 2nd respondent shall thereafter proceed to pass appropriate orders as expeditiously as possible.
8.It is made clear that the period between the date of this order and the receipt of its copy shall be excluded for the purpose of limitation.
9.This Writ Petition stands disposed of with the above observations.
