Rajesh Somandas Sachdev vs Income Tax Officer(Shri. Vilas V … on 22 July, 2026

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    Bombay High Court

    Rajesh Somandas Sachdev vs Income Tax Officer(Shri. Vilas V … on 22 July, 2026

    Author: Madhav J. Jamdar

    Bench: Madhav J. Jamdar

                                                        CNR No : HCBM010560372025
                                                      912-WP-5692-2025+.DOC
    
    
    
    
              IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                     CRIMINAL APPELLATE JURISDICTION
                      WRIT PETITION NO.5692 OF 2025
    
    
    Rajesh Somandas Sachdev                               ...Petitioner
          Versus
    Income Tax Officer & Ors.                             ...Respondents
    
    
    Ms. Rutuja N. Pawar (through Video Conferencing) a/w. Ms. Sneha
    More and Ms.Tejal Mhatre, for the Petitioner.
    Mr. Subir Kumar a/w. Ms. Ashita Aggarwal, for the Respondent
    Nos.1 and 2.
    Mr. S. V. Walve, APP, for Respondent No.3.
    
    
                            CORAM:      MADHAV J. JAMDAR, J.
                            DATED :     22nd JULY 2026
    JUDGMENT:

    1. Heard Ms. Pawar, learned Counsel appearing for the

    Petitioner and Mr. Kumar, learned Counsel appearing for the

    SPONSORED

    Respondent Nos.1 and 2 and Mr. Walve, learned APP appearing for

    Respondent No.3-State.

    2. By this Writ Petition, filed under Articles 226 and 227 of the

    Constitution of India, the Petitioner seeks the quashing and setting

    aside of the Criminal Complaint No.SW/535/2018 pending on the

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    file of the learned Additional Chief Metropolitan Magistrate, 38 th

    Court, Ballard Pier, Mumbai.

    3. It is the submission of the learned Counsel appearing for the

    Petitioner that the Petitioner has filed the Income Tax Returns on

    10th September 2018 for the Assessment Year 2014-2015. It is

    submitted that although there is substance in the contention of the

    learned Counsel appearing for Respondent Nos.1 and 2 that the

    the Income Tax Returns were filed pursuant to a Notice under

    Section 148 of the Income Tax Act 1961 (for short “the said Act”),

    however, she submits that in fact, the Petitioner is seeking a refund

    in the said Income Tax Returns of Rs.1,64,340/-. Therefore,

    learned Counsel appearing for the Petitioner submits that the

    Petitioner’s case will be covered by the proviso to Section 276CC,

    specifically sub-clause ii(b) of the said Act. To substantiate her

    contention, she relies on the decisions of the Supreme Court in the

    case of Guru Nanak Enterprises vs. Income-tax Officer 1 and also

    relies on the two decisions of the Madras High Court in the case of

    1 (2005) 10 SCC 451

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    Rajkumar Thiyagarajan vs. Income Tax Department, Madurai 2and

    Manav Menon vs. Deputy Commissioner of Income-tax3

    4. On the other hand, Mr. Subir Kumar, learned Counsel

    appearing for Respondent Nos.1 and 2 submits that in the facts

    and circumstances, the proviso to Section 276CC, sub-clause ii(b)

    does not apply as it is only applicable to regular assessments. It is

    submitted that in this case, the Income Tax Returns were filed

    after a Notice was issued under Section 148 of the said Act on 18 th

    September 2017 and after the initiation of the criminal prosecution

    on 7th March 2018. The learned Counsel relies on Sections 2(40),

    143(3), 147, 148 and 276CC of the said Act. He submits that as

    the Petitioner has not filed the Income Tax Returns within the

    prescribed time, the offence under Section 276CC of the said Act is

    made out and therefore, no interference is required. However, he

    fairly admits that as per the Income Tax Returns filed by the

    Petitioner and the subsequent Assessment Order dated 26 th

    December 2018, the Petitioner is entitled for a refund of

    Rs.1,64,340/-.

    2 (2021) 124 taxmann.com 119 (Madras)
    3 2023 SCC OnLine Mad 8091

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    5. A perusal of the record shows that as the Petitioner failed to

    file the Income Tax Returns for the Assessment Year 2014-2015, a

    Notice under Section 148 of the said Act was issued to the

    Petitioner on 18th September 2017. Despite the issuance of the said

    Notice, the Income Tax Returns were not filed. Consequently,

    Criminal Complaint being C.C. No.SW/535/2018 was filed against

    the Petitioner on 7th March 2018 for the offence under Section

    276CC of the Income Tax Act.

    6. It is an admitted position that thereafter on 10 th September

    2018, the Petitioner filed the Income Tax Returns for the

    Assessment Year 2014-2015. The said Income Tax Returns show

    that the Tax Deducted at Source (TDS) for the Petitioner was

    Rs.2,54,788/- and that the Petitioner is entitled for a refund of

    Rs.1,64,340/-. The said Income Tax Return was subsequently

    accepted and confirmed by the Assessment Order.

    7. Learned Counsel appearing for the Department fairly admits

    that as per the Income Tax Returns filed by the Petitioner and

    subsequent Assessment Order, the Petitioner is entitled for a refund

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    of Rs.1,64,340/-. In these circumstances, Section 276CC and more

    particularly, proviso ii(b) is relevant and the same reads as under:

    “Failure to furnish returns of income.

    276CC. If a person wilfully fails to furnish in due
    time the return of fringe benefits which he is
    required to furnish under sub-section (1) of section
    115WD
    or by notice given under sub-section (2) of
    the said section or section 115WH of or the return
    of income which he is required to furnish under
    sub-section (1) of Section 139 or by notice given
    under clause (i) of sub-section (1) of section 142 or
    section 148 or section 153A, he shall be punishable,

    (i) in a case where the amount of tax, which would
    have been evaded if the failure had not been
    discovered, exceeds twenty-five hundred thousand
    rupees, with rigorous imprisonment for a term
    which shall not be less than six months which may
    extend to seven years and with fine;

    (ii) in any other case, with imprisonment for a term
    which shall not be less than three months but which
    may extend to two years and with fine:

    Provided that a person shall not be proceeded
    against under this section for failure to furnish in
    due time the return of fringe benefits under sub-
    section (1) of section 115WD or return of income
    under sub-section (1) of section 139-

    (i) for any assessment year commencing prior to the
    first day of April, 1975; or

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    (ii) for any assessment year commencing on or after
    the 1st day of April, 1975, if–

    (a) the return is furnished by him before the
    expiry of the assessment year; or

    (b) the tax payable by him on the total income
    determined on regular assessment, as reduced
    by the advance tax, if any, paid, and any tax
    deducted at source, does not exceed three
    thousand rupees.”

    (Emphasis added)

    Thus, what is provided by Section 276 of the said Act is that

    if a person wilfully fails to furnish in due time and the return of

    income which he is required to furnish under sub-section (1) of

    Section 139 of the said Act then the said offence is punishable.

    However, proviso to Section 276CC of the said Act provides that if

    the tax payable by him on the total income determined on regular

    assessment, as reduced by the advance tax, if any, paid, and any

    tax deducted at source, does not exceed three thousand rupees

    then such a person shall not be proceeded with.

    8. In view of the above provision of Section 276CC, the

    decision of the Supreme Court in the case of Guru Nanak

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    Enterprises (supra) and more particularly, the paragraph Nos.5 to

    8 of the same are relevant, which read as under:

    “5. It appears to us that the case of the appellant is
    clearly covered by proviso (ii)(b) of Section 276-CC.
    In the instant case as noticed, the total tax liability
    of the appellant was finally assessed at Rs 1360.
    Under Section 276-CC proviso (ii)(b), shorn of
    unnecessary details, a person shall not be proceeded
    against under this section for failure to furnish in
    due time the return of income if the tax payable by
    him on the total income determined, as reduced by
    advanced tax, if any, paid, and any tax deducted at
    source, does not exceed Rs 3000. As noticed earlier,
    the appellant had disclosed a tax liability of Rs 644
    which on final assessment was determined as Rs
    1360.

    6. Counsel for the Revenue could not advance any
    argument to support the prosecution launched
    against the appellant, because it is clear that the
    total income tax liability determined by the
    department is only Rs 1360 which is much less than
    Rs 3000 envisaged under the proviso.

    7. We, therefore, find in the facts and circumstances
    of the case, that the prosecution is wholly
    unwarranted. Accordingly, we set aside the
    judgment and order of the High Court and quash
    the proceeding pending against the appellant in the
    Court of the Special Judicial Magistrate (Economic
    Offences), Jaipur on the basis of the complaint
    lodged by the Income Tax Officer, District Circle II,
    Jaipur on 31-3-1986.

    8. This appeal is accordingly, allowed.”

    (Emphasis added)

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    9. In the said case, before the Supreme Court tax liability was

    Rs.1,316 which was well within the statutory limit of Rs.3,000/-.

    This threshold has since been increased to Rs.10,000/-. In the

    present case, however, the Petitioner is actually entitled for a

    refund of Rs.1,64,340/-. Thus, the above observations of the

    Supreme Court are squarely applicable to the present case. The

    two decisions of the Madras High Court also confirm this legal

    position.

    10. It is also pertinent to note that while sanctioning

    prosecution, the Commissioner of Income Tax failed to consider

    that a TDS amount of Rs.2,54,788/- had already been deducted.

    11. Although Mr. Subir Kumar, learned Counsel appearing for

    the Department submits that the said proviso is not applicable to

    this case, however, it is an admitted position that there is no loss to

    the revenue and that the Petitioner is entitled for the

    aforementioned refund. Consequently, in these facts and

    circumstances, the Petitioner is entitled to the relief sought.

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    12. It is settled legal position that inherent jurisdiction under

    Section 482 should be exercised sparingly, carefully and with

    caution and only when such exercise is justified by the tests

    specially laid down in the section. The Court is duty-bound to

    exercise its jurisdiction under Section 482CrPC when the exercise

    of such power is justified by the tests laid down in the said section.

    Jurisdiction under Section 482CrPC must be exercised if the

    interest of justice so requires. The same principle will apply to

    Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

    13. The factual position on record clearly shows that as the

    Petitioner failed to file the Income Tax Returns for the Assessment

    Year 2014-2015, a Notice under Section 148 of the said Act was

    issued to the Petitioner on 18th September 2017. Despite the

    issuance of the said Notice, the Income Tax Returns were not filed.

    Consequently, Criminal Complaint being C.C. No.SW/535/2018

    was filed against the Petitioner on 7th March 2018 for the offence

    under Section 276CC of the Income Tax Act. It is an admitted

    position that thereafter on 10 th September 2018, the Petitioner

    filed the Income Tax Returns for the Assessment Year 2014-2015.

    The said Income Tax Returns show that the Tax Deducted at Source

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    (TDS) for the Petitioner was Rs.2,54,788/- and that the Petitioner

    is entitled for a refund of Rs.1,64,340/-. The said Income Tax

    Return was subsequently accepted and confirmed by the

    Assessment Order. Thus, the case is covered by the Supreme Court

    in the case of Guru Nanak Enterprises (supra). Thus, in the facts

    and circumstances, it is necessary to grant the relief sought in the

    Writ Petition to secure the ends of justice.

    14. Thus, in the facts and circumstances of the case, the criminal

    prosecution is wholly unwarranted and the same would amount to

    an abuse of the process of law.

    15. For the above reasons, the Petitioner is entitled for the relief

    in terms of the prayer clause (a).

    16. Accordingly, the Writ Petition is disposed of in above terms.

    [MADHAV J. JAMDAR, J.]

    Digitally
    signed by
    SONALI
    SONALI MILIND
    MILIND PATIL
    PATIL Date:

    2026.07.25
    16:27:52
    +0530

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    Sonali

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