In an unusual but pragmatic procedural direction, the bench granted liberty to the Income-Tax department to revive the writ petition if the Supreme Court eventually overturns the Hexaware decision.
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Storyboard11-12-2025, 08:36

Bombay HC quashes ₹289 Cr tax notice for Culver Max; FAO rule key.

  • Culver Max Entertainment (formerly Sony Pictures Networks India) faced an Income Tax Department charge of understating taxable income by ₹289.91 crore for Assessment Year 2019-20.
  • The Income Tax Department attempted to reopen Culver Max's assessment, alleging underreporting due to various claims including CSR deductions and depreciation.
  • Culver Max contested the reassessment in the Bombay High Court, arguing the department's conclusions lacked new material and the process was without jurisdiction.
  • The Bombay High Court quashed the reassessment notice, ruling it invalid because it was not issued by a Faceless Assessing Officer, citing the Hexaware Technologies Ltd vs ACIT judgment.
  • The court allowed the IT department to revive the petition if the Supreme Court overturns the Hexaware decision, as the issue of who can issue reassessment notices remains sub-judice.

Why It Matters: A procedural error nullifies a ₹289 crore tax demand, impacting future tax reassessment cases.

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