Saroj Kumar Sahoo v. National Faceless Assessment Centre & Anr. (W.P.(C) No. 30861 of 2025) was decided by the Orissa High Court on 18 February 2026 by a Bench comprising Hon’ble Chief Justice Harish Tandon and Hon’ble Justice Murahari Sri Raman. The Court dismissed a writ petition challenging a faceless income tax assessment order passed under Section 143(3) read with Sections 144B and 260 of the Income Tax Act, holding that the Assessing Officer had jurisdiction to proceed with a block assessment under Chapter XIV-B based on incriminating material. It was held that the challenge involved disputed questions of fact and that, in view of the availability of an effective statutory appellate remedy, the High Court would not exercise writ jurisdiction under Articles 226 and 227, leaving the petitioner to pursue remedies under the Income Tax Act.

Issue of Law

The court examined the maintainability of a writ petition under Articles 226 and 227 of the Constitution of India, challenging an income tax assessment order. Specifically, the issue was whether the Assessing Officer had the jurisdiction to proceed with a "block assessment" under Chapter XIV-B of the Income Tax Act, 1961, and whether the High Court should intervene in matters involving disputed questions of fact when an alternative statutory remedy (appeal) is available.

Facts

The Assessment Dispute

• The Petitioner: Saroj Kumar Sahoo, an individual taxpayer from Kendujhar, Odisha.
• The Order Challenged: An Assessment Order dated March 17, 2025, passed under Section 143(3) read with Sections 260 and 144B of the Income Tax Act for the Assessment Year 2022-23.
• Petitioner's Argument: The petitioner contended that the assessment was invalid as it failed to follow the specific provisions of Section 158BA(2) regarding the assessment of "undisclosed income" for a block period. He argued that the authorities lacked jurisdiction to proceed as they did.

The Department's Stand

The Income Tax Department (Opposite Parties) contended that the Assessing Officer possessed the requisite jurisdiction. They argued that incriminating material had been found, justifying the proceedings under Chapter XIV-B for the block period.

Judgment Discussion

The High Court dismissed the writ and found that the Assessing Officer indeed had the jurisdiction to proceed under Chapter XIV-B of the Act, as undisclosed income was identified based on incriminating material found during the relevant period. The Court noted that the challenges raised by the petitioner involved significant "disputed questions of fact". Such matters are typically not suited for determination in a summary proceeding under the High Court's extraordinary writ jurisdiction. Citing the Supreme Court precedent in Commissioner of Income Tax vs. Chhabil Dass Agarwal, the Court emphasized that it is "loath to exercise extraordinary jurisdiction" when the petitioner has not exhausted the statutory remedies provided under the Income Tax Act. The Court held that no case was made out to invoke Article 226 to "intermeddle" with the Assessment Order. The writ petition was dismissed, leaving the petitioner to pursue standard statutory appeals.

Subsequent Development

• The writ petition and all pending interlocutory applications were disposed of/dismissed.

• The petitioner remains free to challenge the assessment order through the appellate authorities designated under the Income Tax Act.

Access the Whole Judgment here

Court

Orissa High Court

Case Title

Saroj Kumar Sahoo vs.  National Faceless Assessment Centre and Assistant Commissioner of Income Tax

Case Number

W.P.(C) No. 30861 of 2025

Bench

Honourable Chief Justice Mr. Harish Tandon And Honourable Justice Mr. Murahari Sri Raman

Date of Judgment

Pronounced on February 18, 2026