SHRI DEO KISHAN ACHARYA vs. INCOME TAX OFFICER

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CW/12876/2022HC Rajasthan20 March 2025Author: PUSHPENDRA SINGH BHATI, MUNNURI LAXMAN26 pages
AI SummaryPartly Allowed

What did the High Court hold?

The High Court held that the controversy in the present batch of writ petitions concerns the same issue of law as settled in the case of 'Sharda Devi Chhajer (supra)', which dealt with the dispute regarding the jurisdiction of Faceless and Jurisdictional Assessing Authorities. Based on the joint prayers and the consensus arrived at between the parties, the Court declared the notices issued by the Jurisdictional Assessing Officers as illegal and quashed them. The respondents were granted liberty to proceed via the mode of Faceless Assessment in terms of the judgment in 'Sharda Devi Chhajer (supra)'. The period during which the petitions remained pending before the Court was to be excluded for the Faceless Assessing Officer proceedings. Any issues of limitation were to be decided by the Assessing Officer in terms of 'Rajeev Bansal (supra)'. The Court also clarified that any further proceedings under the Faceless Assessment Scheme must be strictly in accordance with law, and any other unadjudicated issues could be agitated again before the Court.

What were the facts?

This judgment consolidates multiple writ petitions filed by various assessees, including M/s S.m. Industries, Vidhya Industries Private Limited, Vibha Bishnoi, and others, against the Income Tax Department. The core of the dispute revolves around notices issued for reopening assessments, specifically orders under Section 148A(d) and notices under Section 148 of the Income Tax Act, 1961. The assessment years involved are not explicitly stated for all petitions but are mentioned as 2013-14 in one instance. The procedural history indicates that these petitions were filed challenging the validity of these notices and the proceedings initiated for reassessment.

What were the issues?

1. Whether the notices issued under Section 148A(d) and Section 148 of the Income Tax Act, 1961, for reopening of assessment are illegal and liable to be quashed, particularly concerning the jurisdiction of the assessing officer. Assessee's Contention: The assessees argued that the notices and subsequent proceedings initiated for reopening of assessment were illegal. They specifically raised a limited issue concerning the jurisdiction of a Faceless Assessing Officer versus a Jurisdictional Assessing Officer, seeking to keep other issues open for future adjudication. They relied on the High Court's prior decision in 'Sharda Devi Chhajer (supra)' regarding the dispute between Faceless and Jurisdictional Assessing Authorities. Revenue's Contention: The judgment does not explicitly record the revenue's specific arguments on the merits of each case. However, it notes that the parties arrived at a consensus on the limited issue presented.

Which sections of the Income-tax Act were involved?

Section 148A,Section 148,Section 147,Section 153

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
[2025:RJ-JD:5826-DB] (1 of 26) [CW-3270/2023] HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JODHPUR D.B. Civil Writ Petition No. 3270/2023 M/s S.m. Industries, G-310, 311, 316 And 317, Agro Food Park Udhyog Vihar, Sriganganagar (Raj.) Through Partner Rajotia S/o Shri Daulat Ram Rajotia, Aged About 67 Years ----Petitioner Versus 1. Union Of India, Through Ministry Of Finance, Department Of Income Tax, North Block, New Delhi. 2. The Income Tax Officer, Ito Ward-1, Sriganganagar (Raj.) ----Respondents Connected With D.B. Civil Writ Petition No. 15947/2021 Vidhya Industries Private Limited, F-92, Mandia Road, Industrial Area-Iii, Pali-Marwar, Rajasthan Through Its Director Jawari Lal Porwal S/o Shri Champalal, Aged About 69 Years, R/o 35/36, Khod Ka Bass, Pali-Marwar, Rajasthan 306401 ----Petitioner Versus Income Tax Officer, Ward -1, Mandia Road, Pali Marwar 306401 ----Respondent D.B. Civil Writ Petition No. 1965/2022 Vibha Bishnoi W/o Bhera Ram Bhadu, Aged About 59 Years, By Caste Bishnoi, Resident Of 6/02 Arid Forest Research Institute (Afri), Main Campus, New Pali Road, Jodhpur- 342005 (Rajasthan). ----Petitioner Versus 1. Income Tax Officer, Income Tax Office, W-1 (2), Aaaykar Bhawan, Paota C Road, Jodhpur-342010 2. Union Of India, Through Its Secretary, Central Board Of Direct Taxes, Department Of Revenue, Ministry Of Finance, North Block, New Delhi (Nct) - 110001. ----Respondents D.B. Civil Writ Petition No. 4618/2022 Amar Pratap Developers Pvt. Ltd., A-21, Sadulgarnj, Bikaner 331001, Rajasthan, Through Its Director Shri Avinash Modi S/o Shri Arun Kumar Modi, Aged About 43 Years, R/o 1St Floor, A- 21, Sadulganj, Bikaner. ----Petitioner Versus 1. Office Of The Asst. Comm. Of Income Tax, Bkn., Acit Circle -1, Bikaner, Aayakar Bhawan, Rani Bazar, Bikaner, (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (2 of 26) [CW-3270/2023] Rajasthan - 334401 2. Income Tax Officer, National Faceless Assessment Center, Room No. 401, 2Nd Floor, E-Ramp, Jawaharlal Nehru Stadium, Delhi 110003 ----Respondents D.B. Civil Writ Petition No. 4750/2022 Amar Pratap Developers Private Limited, A-21, Sadulganj, Bikaner - 334001, Rajasthan, Through Its Director Shri Avinash Modi S/o Shri Arun Kumar Modi, Aged About 43 Years, R/o 1St Floor, A-21, Sadulganj, Bikaner. ----Petitioner Versus 1. Office Of The Assistant Commissioner Of Income Tax, Acit Circle - 1, Bikaner, Aayakar Bhawan, Rani Bazar, Bikaner, Rajasthan - 334401. 2. Income Tax Officer, National Faceless Assessment Center, Room No. 401, 2Nd Floor, E-Ramp, Jawaharlal Nehru Stadium, Delhi - 110003. ----Respondents D.B. Civil Writ Petition No. 6310/2022 Mohit Agarwal S/o Shri Sushil Agarwal, Aged About 31 Years, 21, Residency Road Opposite Manidhari Hospital, Jodhpur (Rajasthan). ----Petitioner Versus 1. Principal Commissioner Income Tax Jodhpur-1, Aaykar Bhawan, Jodhpur (Rajasthan). 2. Deputy Director (Investigation), Jodhpur (Rajasthan). 3. Income Tax Officer, W-3(1), Ju, Aayakar Bhawan, Paota C-Road, Jodhpur (Rajasthan). ----Respondents D.B. Civil Writ Petition No. 6440/2022 Prakash Mehta S/o Shankerlal, Aged About 70 Years, C-5, Jineshwar Kumar Amritlal Jain Basni Mandi Jodhpur Rajasthan. ----Petitioner Versus 1. Union Of India, Through The Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi. 2. The Principal Commissioner Of Income Tax, Jodhpur-1 Aaykar Bhawan, Paota C Road, Jodhpur-342010 3. The Assistant Commissioner Of Income Tax, Circle-1, Jodhpur, Aaykar Bhawan, Paota C Road, Jodhpur-342010 4. The Assistant Commissioner Of Income Tax, Nfac, Delhi, National Faceless Assessment Centre Through Pr. (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (3 of 26) [CW-3270/2023] Commissioner Of Income Tax, Jodhpur-1 Aaykar Bhawan, Paota C Road, Jodhpur-342010 ----Respondents D.B. Civil Writ Petition No. 7043/2022 Hukum Singh Ninama S/o Kachru Singh Ninama, Aged About 49 Years, Ward No-3 Muvalpada Ganau, Jhupal Banswara 327001, Rajasthan ----Petitioner Versus Income Tax Officer, Banswara, Maharana Pratap Circle, Udaipur Main Road, Banswara, Banswara, Rajasthan, 327001 ----Respondent D.B. Civil Writ Petition No. 7217/2022 Vidhya Industries Private Ltd., F-92, Mandia Rod, Industrial Area-Iii, Pali-Marwar, Rajasthan Through Its Director Jawari Lal Porwal S/o Shri Champalal, Aged About 69 Years, R/o 35/36, Khod Ka Bass, Pali- Marwar, Rajasthan 306401. ----Petitioner Versus Office Of The Income Tax Officer, Ito, Ward-1, Mandia Road, Pali Marwar 306401. ----Respondent D.B. Civil Writ Petition No. 10238/2022 Manoj Daga W/o Shri Surendra Mal Daga, Aged About 61 Years, 59, Dev Nagar, Pal Link Road, Jodhpur -342 001 (Rajasthan) ----Petitioner Versus 1. The National Faceless Assessment Center, Income Tax Department, Ministry Of Finance, Inside Jawaharlal Nehru Stadium, New Delhi. 2. The Income Tax Officer, Ward - 3 (1), Income Tax Department, Aayakar Bhawan, Paota 'c' Road, Jodhpur 342 010. ----Respondents D.B. Civil Writ Petition No. 11219/2022 Rnp Steels Pvt. Ltd., Plot No. 12, Road No. 6, Mia Iind Phase, Basni, Jodhpur. Through Its Director, Niranjan Agarwal, Aged 60, S/o Shri Mahaveer Prasad Agarawal, R/o Rooprajat Township, Pal Road, Jodhpur (Rajasthan). ----Petitioner Versus 1. Union Of India, Through The Secretary To The Government Of India, Ministry Of Finance, Department Of Revenue, New Delhi. 2. The Income Tax Officer, Ward - 1(1), Income Tax (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (4 of 26) [CW-3270/2023] Department, Aayakar Bhawan, Paota C Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 11586/2022 Ganga Steels, Through The Partner, Jitendra Jain S/o Babulalji Jain, Aged About 45 Years Jodhpur (Raj.) ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi 2. The Income Tax Officer, Ward - 1(2), Income Tax Department, Paota C Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 12235/2022 Harka Ram Somani S/o Shri Ram Kumar Somani, Aged About 73 Years, R/o - 22, Kanchipuram, Bhilwara - 311001 (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi ----Respondents D.B. Civil Writ Petition No. 12358/2022 Hemant Gokhru S/o Phool Chand Gokhru, Aged About 65 Years, R/o 93 Panchwati, Udaipur 313001, Rajasthan ----Petitioner Versus 1. Union Of India, Through Secretary Finance, Ministry Of Finance, North Block, New Delhi 110001. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi 4. The Income Tax Officer, Ward No. 1, Bhilwara (Raj.). ----Respondents D.B. Civil Writ Petition No. 12362/2022 Pushpa Gokhru W/o Rajendra Gokhru, Aged About 62 Years, R/o 36 Main Sector, Shastri Nagar, Bhilwara 311001, Rajasthan ----Petitioner (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (5 of 26) [CW-3270/2023] Versus 1. Union Of India, Through Secretary Finance, Ministry Of Finance, North Block, New Delhi 110001. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi 4. The Income Tax Officer, Ward No. 1, Bhilwara (Raj.). ----Respondents D.B. Civil Writ Petition No. 12364/2022 Rajendra Gokhru S/o Phool Chand Gokhru, Aged About 63 Years, R/o 36 Main Sector, Shastri Nagar, Bhilwara 311001, Rajasthan. ----Petitioner Versus 1. Union Of India, Through Secretary Finance, Ministry Of Finance, North Block, New Delhi 110001. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi 4. The Income Tax Officer, Ward No. 1, Bhilwara (Raj.). ----Respondents D.B. Civil Writ Petition No. 12611/2022 Rajesh Kumar Somani S/o Shri Harka Ram Somani, Aged About 51 Years, R/o 21, Kanchipuram, Bhilwara 311001 (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. The Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi ----Respondents D.B. Civil Writ Petition No. 12613/2022 Jamna Devi Somani W/o Shri Harka Ram Somani, Aged About 67 Years, R/o - 22, Kanchipuram, Bhilwara - 311001 (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (6 of 26) [CW-3270/2023] Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. The Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi ----Respondents D.B. Civil Writ Petition No. 12771/2022 Gaurav Kumar Kothari S/o Shri Kanakmal Kothari, Aged About 41 Years, R/o Oswal Kothari Mohalla, Churu (Rajasthan) 33001, Presently Residing In Delhi ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. The Income Tax Officer, Ward No. 1, Churu (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi ----Respondents D.B. Civil Writ Petition No. 12833/2022 Shri Deo Kishan Acharya S/o Shri Bardi Chand Acharya, Aged About 53 Years, Resident Of 3-H-13/14, R.c. Vyas Colony, Bhilwara (Rajasthan) - 311001. ----Petitioner Versus 1. Income Tax Officer, Ito Ward (1), Kawa Khera Chourha, Shashtri Nagar, Bhilwara (Rajasthan) - 311001. 2. Office Of Principal Chief Commissioner Of Income Tax, Income Tax Department, Ncr Building, Statue Circle, Jaipur (Rajasthan) - 302005. 3. Central Board Of Direct Taxes, Through Chairperson, Type-7, Bungalow No. 75, New Moti Bagh, New Delhi - 110021. ----Respondents D.B. Civil Writ Petition No. 12876/2022 Shri Deo Kishan Acharya S/o Shri Bardi Chand Acharya, Aged About 53 Years, Resident Of 3-H-13/14, R.c. Vyas Colony, Bhilwara (Rajasthan) - 311001. ----Petitioner Versus 1. Income Tax Officer, Ito Ward (1), Kawa Khera Chourha, (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (7 of 26) [CW-3270/2023] Shashtri Nagar, Bhilwara (Rajasthan) - 311001. 2. Office Of Principal Chief Commissioner Of Income Tax, Income Tax Department, Ncr Building, Statue Circle, Jaipur (Rajasthan) - 302005. 3. Central Board Of Direct Taxes, Through Chairperson, Type-7, Bungalow No. 75, New Moti Bagh, New Delhi - 110021. ----Respondents D.B. Civil Writ Petition No. 12891/2022 Dilip Raj Singhvi S/o Shri Bachchraj Ji Singhvi, Aged About 59 Years, D-160, Shastri Nagar, Jodhpur, Rajasthan . Pan No. Ainps1239A ----Petitioner Versus Income Tax Officer, Ward-1(1), Jodhpur, Rajasthan. ----Respondent D.B. Civil Writ Petition No. 12949/2022 Shreenath Residency Developers Private Limited, Through Its Director Shri Praveen Kumar Shrimali, Aged About 53 Years, R/o Tehsil Road, Nathdwara, Rajsamand (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Deputy Commissioner Of Income Tax, Central Circle-1, Aaykar Bhawan, Subcity Centre, Savina, Udaipur (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 12979/2022 Dilip Raj Singhvi S/o Shri Bachchraj Ji Singhvi, Aged About 59 Years, R/o D-160, Shastri Nagar, Jodhpur, Rajasthan. (Pan No. Ainps1239A) ----Petitioner Versus Income Tax Officer, Ward- 1(1), Jodhpur, Rajasthan. ----Respondent D.B. Civil Writ Petition No. 12994/2022 Dilip Raj Singhvi S/o Shri Bachchraj Ji Singhvi, Aged About 59 Years, R/o D-160, Shastri Nagar, Jodhpur, Rajasthan. ----Petitioner (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (8 of 26) [CW-3270/2023] Versus Income Tax Officer, Ward No. (1), Jodhpur, Rajasthan. ----Respondent D.B. Civil Writ Petition No. 13036/2022 Shri Deo Kishan Acharya S/o Shri Bardi Chand Acharya, Aged About 53 Years, 3-H-13/14, R.c. Vyas Colony, Bhilwara (Rajasthan) 311001 ----Petitioner Versus 1. Income Tax Officer, Ito Ward (1), Kawa Khera Chourha, Shashtri Nagar, Bhilwara (Rajasthan) - 311001 2. Office Of Principal Chief Commissioner Of Income-Tax, Income-Tx Department, Ncr Building, Statue Circle, Jaipur (Rajasthan)-302005 3. Central Board Of Direct Taxes, Through Chairperson, Type-7 Bungalow No. 75, New Moti Bagh, New Delhi 110021 ----Respondents D.B. Civil Writ Petition No. 13053/2022 M/s Shree Mahesh Oil Products, Through Its Partner Shri Ramesh Chandra Toshniwal 9Age 59 Years), Having Office At 1St Floor, 147-148, Bazar No. 2, Near Vijay Hotel, Bhilwara (Rajasthan) 311001 ----Petitioner Versus 1. Income Tax Officer, Ito Ward (1), Kawa Khera Chourha, Shashtri Nagar, Bhilwara (Rajasthan) - 311001 2. Principal Chief Commissioner Of Income-Tax, Income-Tx Department, Ncr Building, Statue Circle, Jaipur (Rajasthan)-302005 3. Central Board Of Direct Taxes, Through Chairperson, Type-7 Bungalow No. 75, New Moti Bagh, New Delhi 110021 ----Respondents D.B. Civil Writ Petition No. 13055/2022 Hakim Khan S/o Inayat Khan, Aged About 60 Years, R/o Ward No. 31, Aguna Mohalla, Churu (Rajasthan) 33001, Presently Residing In Dubai, Uae, In Capacity Of Proprietor Of Hotel Suncity Palace, Churu. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (9 of 26) [CW-3270/2023] 3. Income Tax Officer, Ward No. 1, Churu (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 13128/2022 Nitin Spinners Limited, 16-17 Km. Stone, Chittor Road, Hameergarh, Bhilwara, Through Its Company Secretary And General Manager (Legal), Sudhir Garg S/o Shri Hari Kishan Das, Aged 56 Years, Resident Of E-9, Basant Vihar Bhilwara. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 13176/2022 Hakim Khan S/o Inayat Khan, Aged About 60 Years, R/o Ward No. 31, Presently Residing In Dubai, Uae, Aguna Mohalla, Churu (Rajasthan) 33001 In Capacity Of Proprietor Of Hotel Suncity Palace, Churu. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Churu (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 13188/2022 Rakesh Kumar Jain S/o Shri Gautam Chand Jain, Aged About 41 Years, C/o Gautam Chand, A-122, Ist Extension, Kamla Nehru Nagar, Jodhpur. ----Petitioner Versus 1. Principal Commissioner Of Income Tax-1, Aaykar Bhawan, Paota C Road, Jodhpur. (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (10 of 26) [CW-3270/2023] 2. Deputy Commissioner Of Income Tax, Aaykar Bhawan, Paota C Road, Circle-3, Jodhpur. 3. Assistant Commissioner Of Income Tax, Aaykar Bhawan, Paota C Road, Circle-3, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 13509/2022 Sanju Gehlot W/o O.p. Gehlot, Aged About 50 Years, Village Post Salawas, Ditt. Jodhpur - 342804 Rajasthan. ----Petitioner Versus 1. Union Of India, Through Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi. 2. The Principal Commissioner Of Income Tax, Jodhpur-1, Aaykar Bhawan, Paota C Road, Jodhpur 342010 3. The Income Tax Officer, Ward - 3 (1) Jodhpur, Aaykar Bhawan, Paota C Road, Jodhpur 342010 ----Respondents D.B. Civil Writ Petition No. 13519/2022 Ajay Jain S/o Shri Dhiraj Lal Jain, Aged About 44 Years, 77, Shyam Nagar, Pal Link Road, Jodhpur - 342001 (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary To The Government Of India, Ministry Of Finance, Department Of Revenue, New Delhi. 2. The Income Tax Officer, Ward - 3 (1), Income Tax Department, Aayakar Bhawan, Paota C Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 13568/2022 Balaji Property, 1, J B Market Athuna Bazar, Ratangarh, District Churu (Raj.) Through Its Partner Tarun Kumar Chaklan, Age 54 Years R/o Shri Babu Lal Chaklan, R/o Ratangarh, District Churu (Raj.), 331022. ----Petitioner Versus 1. Income-Tax Officer, Ito Ward (1), Churu (Raj.). 2. Office Of Principal Chief Commissioner Of Income-Tax, Income - Tax Department, Ncr Building, State Circle, Jaipur (Raj.). 3. Central Board Of Director Taxes, Through Chairperson, Type-7, Bungalow No. 75, New Moti Bagh, New Delhi. ----Respondents D.B. Civil Writ Petition No. 13587/2022 (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (11 of 26) [CW-3270/2023] Shreenath Residency Developers Pvt. Ltd., Through Its Director Shri Praveen Kumar Shrimali, Aged About 53 Years, R/o Tehsil Road, Nathdwara, Rajasmand (Rajasthan). ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Deputy Commissioner Of Income, Central Circle-1, Aaykar Bhawan, Subcity Centre, Savina, Udaipur (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 13644/2022 Dr. Madhu Singhal S/o Shri Ratan Lal Singhal, Aged About 67 Years, 561, Near Satsang Bhawan, 7Th Road, Sardarpura, Jodhpur 342 001 (Rajasthan) ----Petitioner Versus 1. Union Of India, Through The Secretary To The Government Of India, Ministry Of Finance, Department Of Revenue, New Delhi. 2. The Income Tax Officer, Ward 1(1), Income Tax Department, Aayakar Bhawan, Paota 'c' Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 14185/2022 Santosh Vaishnav W/o Shri R.p Vaishnav, Aged About 54 Years, R/o Plot No. 6, Arihant Nagar, Pal Road, Nandanwan, Jodhpur 342008, Rajsthnan. ----Petitioner Versus 1. Union Of India, Through Secretary Finance, Ministry Of Finance, North Block, New Delhi-110001. 2. Principal Commissioner Of Income Tax-1St, Aaykar Bhawan, Paota C Road, Jodhpur 342010. 3. Income Tax Officer, Ward 3(1), Aaykar Bhawan, Paota C Road, Jodhpur 342010. ----Respondents D.B. Civil Writ Petition No. 14249/2022 M/s Venkteshwara, House No. 11, E-Block, Sri Ganganagar Through Its Authorized Signatory Rattan Lila S/o Shri Dwarka Dass Lila, Aged About 50 Years, Resident Of House No. 11, E- Block, Sri Ganganagar 335001 (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (12 of 26) [CW-3270/2023] ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Sriganganagar (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 14628/2022 Tayab Ansari S/o Shri Mumtaj Ali Ansari, Aged About 55 Years, C-204, Kamala Nehru Nagar, Jodhpur 342001 ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. Assistant Commissioner Of Income Tax, C-3, Income Tax Department, Paota C Road, Jodhpur (Raj.). ----Respondents D.B. Civil Writ Petition No. 14653/2022 Tulsi Devi Bhootra W/o Shri Om Parkash Bhootra, Aged About 59 Years, R/o Near Maheshwari Nyati Nohra, Masuria Jodhpur (Raj.). ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. Income Tax Officer, Ward 3(1), Income Tax Department, Paota C Road, Jodhpur (Raj.). ----Respondents D.B. Civil Writ Petition No. 14680/2022 Anjana Mines And Minerals, Having Its Office At 1-Anjana Compound, Dak Bungla, Petch Area, Nimbahera, Chittorgarh, Rajasthan, Through Its Manohar Lal Anjana S/o Late Bheru Lal Anjana Aged About 65 Years R/o Village Kesunda Tehsil Chhotisadri, Dist Pratapgarh, Pincode 312604. ----Petitioner Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Income Tax Officer, Ward 1, Chittorgarh, Rajasthan 312001. (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (13 of 26) [CW-3270/2023] ----Respondents D.B. Civil Writ Petition No. 14901/2022 Sharmila Singhvi W/o Shri Manoj Singhvi, Aged About 38 Years, R/o 866, Vimal Kunj, 1St A Road, Sardarpura, Jodhpur 342003 ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi 2. The Income Tax Officer, W 3 (1), Income Tax Department, Paota C Road, Jodhpur (Raj.) ----Respondents D.B. Civil Writ Petition No. 14938/2022 Rajendra Singh Khinchi S/o Purshottam Singh Khinchi, Aged About 54 Years, R/o Khinchi House, Tekri Madri Link Road, Udaipur 313001, Rajasthan. ----Petitioner Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Income Tax Officer, Ward 2(1), Udaipur, Rajasthan 313001. ----Respondents D.B. Civil Writ Petition No. 14942/2022 Shilpa Singhvi W/o Shri Mukesh Singhvi, Aged About 40 Years, R/o 866, Vimal Kunj, 3Rd A Road, Sardarpura, Jodhpur 342003 ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi 2. Assistant Commissioner Of Income Tax, C-3, Income Tax Department, Paota C Road, Jodhpur (Raj.) ----Respondents D.B. Civil Writ Petition No. 15166/2022 Prakash Kumar S/o Roopa Ram Kumhar, Aged About 50 Years, R/ o Near Bus Stand, Village Lunawa, Bali Road, Dist. Pali. ----Petitioner Versus 1. The Union Of India, Through Ministry Of Finance, Income Tax Department, Government Of India, New Delhi. 2. The Principal Chief Commissioner, Income Tax Department, Rajasthan, Jaipur. 3. Income Tax Officer, Jodhpur. 4. Deputy Commissioner Of Income Tax, Central Circle Ii, Jodhpur. (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (14 of 26) [CW-3270/2023] ----Respondents D.B. Civil Writ Petition No. 15220/2022 M/s Venkteshwara, House No. 11, E-Block, Sri Ganganagar Through Its Authorized Signatory Rattan Lila S/o Shri Dwarka Dass Lila, Aged About 50 Years, Resident Of House No. 11, E- Block, Sri Ganganagar 335001. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Sriganganagar (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 15243/2022 Anjana Mines And Minerals, Having Its Office At 1 Anjana Compound, Dak Bungla Road, Petch Area, Nimbahera, Chittorgarh, Rajasthan, Through Its Manohar Lal Anjana S/o Late Bheru Lal Anjana Aged About 65 Years R/o Village Kesunda Tehsil Chhotisadri, Dist Pratapgarh Pincode 312604. ----Petitioner Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Income Tax Officer, Ward 1,chittorgarh, Rajasthan 312001. ----Respondents D.B. Civil Writ Petition No. 15284/2022 Anjana Mines And Minerals, Having Its Office At 1 Anjana Compound, Dak Bungla Road, Petch Area, Nimbahera, Chittorgarh, Rajasthan, Through Its Manohar Lal Anjana S/o Late Bheru Lal Anjana Aged About 65 Years R/o Village Kesunda Tehsil Chhotisadri, Dist Pratapgarh Pincode 312604. ----Petitioner Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Income Tax Officer, Ward 1,chittorgarh, Rajasthan 312001. ----Respondents D.B. Civil Writ Petition No. 15289/2022 Surendra Jain, Aged About 65 Years, Legal Representative And (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:54 PM) [2025:RJ-JD:5826-DB] (15 of 26) [CW-3270/2023] Son Of Late Shri Sohanmal Malchand Jain, Aged About 65 Years, R/o D-403, Ayodhya Park, Kanwala Naka Kolhapur, Maharashtra 416002. ----Petitioner Versus 1. Union Of India, Through Its Secretary, Ministry Of Finance, Central Board Of Direct Taxes (Cbdt), New Delhi. 2. Income Tax Officer, Sumerpur. ----Respondents D.B. Civil Writ Petition No. 16338/2022 Mahesh Suppliers (India) Pvt. Ltd., Having Its Registered Address At Ram Rajya Chowk, Bhinasar 334403 Rajasthan Through Its Authorised Representative Jagdish Prakash Rathi S/o Ash Karan Rathi Aged About 49 Years R/o Ram Rajya Chowk, Bhinasar Bikaner ----Petitioner Versus Assistant Commissioner Of Income Tax, Circle 1, Rani Bazar, Bikaner, Rajasthan 334001 ----Respondent D.B. Civil Writ Petition No. 16583/2022 M/s Saraansh Suitings Private Limited, 10, New Cloth Market, Pur Road, Bhilwara (Raj.) Through The Director Shri Sandeep Kumar Chordia S/o Shri Sampat Lal Chordia Aged 38 Years ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi 2. The Income Tax Officer, Ward 1, Income Tax Department, Kawa Khera Chouraha, Shastri Nagar, Bhilwara (Raj.) ----Respondents D.B. Civil Writ Petition No. 17312/2022 M/s Silver Fab Suitings Pvt. Ltd., 9, New Cloth Market, Pur Road, Bhilwara, Through The Director Shri Sushil Kumar Chordia S/o Shri Sampat Lal Chordia, Aged 41 Years. ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. The Income Tax Officer, Ward 1, Income Tax Department, Kawa Khera Chouraha, Shastri Nagar, Bhilwara (Raj.) ----Respondents D.B. Civil Writ Petition No. 17339/2022 Priyanka Jain W/o Shri Deepak Jain, Aged About 51 Years, R/o (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (16 of 26) [CW-3270/2023] D-160, Shastri Nagar, Jodhpur, Rajasthan At Present Resident At 5720, Sadar Thana Road, Basti Harphool Singh, Delhi 110006. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commsisioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. 4. Income Tax Officer, Ward-63(1), Delhi. 5. Income Tax Officer, I And C I, Jodhpur, Rajasthan. ----Respondents D.B. Civil Writ Petition No. 17345/2022 Priyanka Jain W/o Shri Deepak Jain, Aged About 51 Years, R/o D-160 Shastri Nagar, Jodhpur, Rajasthan At Present Resident Of 5720, Sadar Thana Road, Basti Harphool Singh, Delhi - 110006. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. 4. Income Tax Officer, Ward-63 (1), Delhi, Rajasthan. 5. Income Tax Officer, I And C I, Jodhpur, Rajasthan. ----Respondents D.B. Civil Writ Petition No. 18519/2022 Suresh Kumar Jain S/o Shri Bhabut Mal Jain, Aged About 54 Years, 125, Suman Villa, Main Sector, Shastri Nagar, Bhilwara 311001 ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. Income Tax Officer, Ward 1, Income Tax Department, Bhilwara (Raj.). ----Respondents D.B. Civil Writ Petition No. 19114/2022 M/s Janki Corp Limited, Mandpiya Chouraha, Chittor Road, Bhilwara, Through The Director Shri Raghunath Mittal S/o Shri (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (17 of 26) [CW-3270/2023] Jai Lal Agarwal Aged 60 Years. ----Petitioner Versus 1. Union Of India, Through The Secretary, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. The Income Tax Officer, Ward-1, Income Tax Department, Bhilwara (Raj.). ----Respondents D.B. Civil Writ Petition No. 19594/2022 Lalu Ram Nuwal S/o Sh. Mohan Lal Nuwal, Aged About 81 Years, R/o Near Mandir, Raipur, Bhilwara 311803. ----Petitioner Versus 1. Union Of India, Through Finance Secretary, Ministry Of Finance (Department Of Revenue), Central Board Of Direct Taxes, North Block, New Delhi. 2. Income Tax Officer, Ward 1, Bhilwara, Kawa Khera Chouraha, Shashtri Nagar, Bhilwara, Rajasthan 311001. 3. Principal Commissioner Of Income Tax Udaipur, Aaykar Bhawan, Subcity Center, Savina, Udaipur 313001. ----Respondents D.B. Civil Writ Petition No. 19596/2022 Late Sh. Sunil Kumar Porwal, S/o Sh. Bal Kishan Porwal, Through His Legal Heir Hansa Devi Porwal W/o Late Sh. Sunil Kumar Porwal, Aged Around 52 Years, R/o G-302, Shilalekh, Opp. Police Stadium, Shahibaug, Ahmedabad 380004. ----Petitioner Versus 1. Income Tax Officer, Ward 1, Chittor, Fort Road, Chittorgarh (Raj.) 312001. 2. Principal Commissioner Of Income Tax Udaipur, Aaykar Bhawan, Subcity Center, Savina, Udaipur 313001. ----Respondents D.B. Civil Writ Petition No. 19616/2022 Hansa Devi Porwal W/o Late Sh. Sunil Kumar Porwal, Aged About 52 Years, R/o - G-302, Shilalekh, Shahi Bagh, Ahemdabad, 380004, Gujarat. ----Petitioner Versus 1. Income Tax Offiver, Ward - 1, Chittorgarh, Fort Road, Chittorgarh Rajasthan - 312001. 2. Principal Commissioner Of Income Tax, Udaipur, Aaykar Bhawan, Subcity Center, Savina, Udaipur - 313001. ----Respondents (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (18 of 26) [CW-3270/2023] D.B. Civil Writ Petition No. 19682/2022 Jangir Singh S/o Nanak Singh, Aged About 63 Years, Chak 28Kyd Khajuwala, Bikaner, Rajasthan 334023. ----Petitioner Versus 1. Office Of The Income Tax Department, Ito Ward-1(1), Bkn, Aaykar Bhawan, Rani Bazar, Bikaner, Rajasthan - 3340001. 2. Central Board Of Direct Taxes, Through Chairperson, Type-7, Bungalow No. 75, New Moti Bagh, New Delhi - 110021 ----Respondents D.B. Civil Writ Petition No. 107/2023 Ashok Mehta S/o Late Shri Jaswant Raj Ji Mehta, Aged About 47 Years, Proprietor Of Sumangal Silk Mills, Shop No. 19, 1St Floor B K Shopping Centre, Tripolia Bazar, Jodhpur And Resident Of 77, Shyam Nagar, Pal Link Road, Jodhpur. ----Petitioner Versus 1. The National Faceless Assessment Centre, Income Tax Department, Ministry Of Finance, Inside Jawaharlal Nehru Stadium, New Delhi. 2. The Deputy Commissioner Of Income Tax, Central Circle 1, Income Tax Department, Aayakar Bhawan, Paota C Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 918/2023 Kamla Devi Darak W/o Lt. Sh. Jagdish Chand Darak, Aged About 76 Years, Near Laxmi Narayan Mandir, Lnt Road, Bhilwara, Rajasthan, 311001 ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 979/2023 Prabhat Automobiles Pvt. Ltd., Registered Office L. N. Temple Road, Bhilwara 311001. Through Its Director Shri Nand Kishore Darak S/o Jagdish Chandra Darak, Aged About 49 Years, (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (19 of 26) [CW-3270/2023] Resident Of Laxmi Narayan Temple Road, Bhilwara. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Bhilwara (Raj.). 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 1249/2023 Harish Kumar Bafna S/o Jeevan Lal Bafna, Aged About 39 Years, R/o Proprietor Of M/s Hari Tyre 189 Chopasani Road, Akhaliya Chouraha, Near Veer Prabhu Sweet Home, Jodhpur, Rajasthan. ----Petitioner Versus 1. Union Of India, Through Secretary Finance Department, Ministry Of Finance, Department Of Revenue, North Block, New Delhi. 2. The Income Tax Officer, Ward-3(1), Income Tax Department, Aayakr Bhawan, Paota C Road, Jodhpur. ----Respondents D.B. Civil Writ Petition No. 1566/2023 Vijay Industries, F-163, 164, Agro Food Park, Boranada, Jodhpur - Rajasthan Through Its Partner Dalpat Mehta S/o Shri Prakash Mehta, Aged About 48 Years, R/o 9Th Pal Road, Bachraj Ji Ka Bagh, Sardarpura, Jodhpur. ----Petitioner Versus 1. Union Of India, Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi. 2. The Principal Commissioner Of Income Tax, Jodhpur-1 Aaykar Bhawan, Paota C Road, Jodhpur - 342010 3. The Income Tax Officer Ward -3 (1), Jodhpur Aaykar Bhawan, Paota C Road, Jodhpur - 342010 ----Respondents D.B. Civil Writ Petition No. 1715/2023 Bhagirath Ram Mehariya S/o Shri Radha Kishan Mehariya, Aged About 53 Years, (A.y. 2013-14), R/o Village Dhigsara, Post Bhed, Tehsil Khinvsar, District Nagaur, Rajasthan 341001. ----Petitioner Versus (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (20 of 26) [CW-3270/2023] 1. Income Tax Officeer, Ward 1, Nagour, In Front Of Br Mirdha College, Manasar Road, Nagaur, Rajasthan 34001. 2. Central Board Of Direct Taxes, Through Its Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi (Nct) 110001. ----Respondents D.B. Civil Writ Petition No. 1716/2023 Bhagirath Ram Mehariya S/o Shri Radha Kishan Mehariya, Aged About 53 Years, (A.y. 2014-15), R/o Village Dhigsara, Post Bhed, Tehsil Khinvsar, District Nagaur, Rajasthan 341001. ----Petitioner Versus 1. Income Tax Officer, Ward 1, Nagour, In Front Of Br Mirdha College, Manasar Road, Nagaur, Rajasthan 34001. 2. Central Board Of Direct Taxes, Through Its Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi (Nct) 110001. ----Respondents D.B. Civil Writ Petition No. 3120/2023 Prabhat Multitrade Pvt. Ltd., Registered Office L.n. Temple Road, Bhilwara 311001, Through Its Director Shri Nand Kishore Darak S/o Jagdish Chandra Darak, Aged About 49 Years, Resident Of Laxmi Narayan Temple Road, Bhilwara. ----Petitioner Versus 1. Union Of India, Through Secretary (Revenue), Ministry Of Finance, North Block, New Delhi. 2. Principal Chief Commissioner Of Income Tax, Jaipur Central Revenue Building, B.d. Road, Jaipur. 3. Income Tax Officer, Ward No. 1, Bhilwara (Raj.) 4. Central Board Of Direct Taxes, Through Chairman, Department Of Revenue, Ministry Of Finance, North Block, New Delhi. ----Respondents D.B. Civil Writ Petition No. 3292/2023 Kanda Edible Oil Pvt. Ltd., E-173, Udhyog Vihar, Sriganganagar (Raj.) ----Petitioner Versus 1. Union Of India, Through Ministry Of Finance, Department Of Income Tax, North Block, New Delhi. 2. The Income Tax Officer, Ito Ward-1, Sriganganagar (Raj.) ----Respondents D.B. Civil Writ Petition No. 4696/2023 (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (21 of 26) [CW-3270/2023] Anncarol Simon W/o Sh. Angelo Mark Simon, Aged About 45 Years, Simon Bungalow, Jhalamand, Jodhpur. ----Petitioner Versus 1. The National Faceless Assessment Centre, Income Tax Department, Ministry Of Finance, Inside Jawaharlal Nehru Stadium, New Delhi. 2. The Income Tax Officer, Ward - 1(1), Income Tax Department, Aayakar Bhawan, Paota C Road, Jodhpur - 342010. ----Respondents D.B. Civil Writ Petition No. 9051/2024 Nirmala Meena W/o Shri Pawan Kumar Mittal, Aged About 59 Years, R/o C/e 72, P.w.d.colony, Jodhpur - 342001 ----Petitioner Versus 1. Union Of India, Through Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi. 2. The National Faceless Assessment Centre, Income Tax Department, Ministry Of Finance, Inside Jawaharlal Nehru Stadium, New Delhi 3. The Income Tax Officer, Ward 1(2) Jodhpur Aaykar Bhawan, Paota C Road, Jodhpur - 342010 ----Respondents D.B. Civil Writ Petition No. 10279/2024 Pawan Kumar Mittal S/o Shri Bajrang Lal Mittal, Aged About 65 Years, R/o 501, Top Flor, Umaid Heritage, Defence Lab Road, Jodhpur- 342006. ----Petitioner Versus 1. Union Of India, Through Secretary, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi. 2. The National Faceless Assessement Centre, Income Tax Department, Ministry Of Finance Inside Jawaharlal Nehru Stadium, New Delhi. 3. The Income Tax Officer, Ward 1(2), Jodhpur Aaykar Bhawan, Paota C Road Jodhpur - 342010. ----Respondents D.B. Civil Writ Petition No. 17104/2024 Hulas Chand Bhutra S/o Late Shri Pannalalji Bhutra, Aged About 74 Years, R/o C-53, Panchsheel Colony, Ajmer Road, Jaipur, Rajasthan. ----Petitioner (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (22 of 26) [CW-3270/2023] Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Income Tax Officer, Ward-1 (1) Bkn, Bikaner, Rajasthan. 3. National Faceless Assessment Centre, 2Nd Floor, E-Ramp, Jawaharlal Nehru Stadium, New Delhi. ----Respondents D.B. Civil Writ Petition No. 17201/2024 M/s J.k. Construction Company, Having Registered Office At 304, Royal Plaza, Sansar Chandra Road, Jaipur Through Its Authorized Signatory, Hulas Chand Bhutra S/o Late Shri Pannalalji Bhutra Aged About 74 Years, R/o C-53, Panchsheel Colony, Ajmer Road, Jaipur, Rajasthan. ----Petitioner Versus 1. Union Of India, Through Secretary, Ministry Of Finance, Department Of Revenue, New Delhi. 2. Assistant Commissioner Of Income Tax, Circle-1, Bkn Income Tax Office, Rani Bazar, Bikaner, Rajasthan. 3. National Faceless Assessment Centre, 2Nd Floor, E-Ramp, Jawaharlal Nehru Stadium, New Delhi. ----Respondents D.B. Civil Writ Petition No. 16678/2022 Vibha Bishnoi W/o Bhera Ram Bhadu, Aged About 59 Years, Resident Of A-68, Krishna Nagar, New Pali Road, Jodhpur, Rajasthan, Pin 342005. ----Petitioner Versus 1. Union Of India, Through Its Secretary, Central Board Of Direct Taxes, Department Of Revenue, Ministry Of Finance, North Block, New Delhi (Nct), Pin 110001. 2. Prinicipal Chief Commissioner Of Income Tax, Jaipur, Having Its Office At Central Revenue Building, B D Road, Jaipur (Raj) 3. Income Tax Officer, Income Tax Office W-1 (2), Ayakar Bhawan, Paota C Road, Jodhpur 342010. ----Respondents For Petitioner(s) : Mr. Sanjeev Johari Sr. Advocate assisted by Mr. Shubhankar Johari Mr. Vikas Balia, Sr. Advocate assisted by Mr. Sachin Saraswat & Mr. Priyansh Arora, (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM) [2025:RJ-JD:5826-DB] (23 of 26) [CW-3270/2023] Mr. Sharad Kothari Mr. Anjay Kothari a/w Mukesh Gurjar Mr. Nikhil Jain, Mr. Falgun Buch, Mr. Pushkar Taimni for Mr. Sanjay Nahar, Mr. Anil Bhansali, Mr. Akshat Verma, Mr. Vineet R Dave Mr. Rajat Arora, Mr. Kapil Purohitm Mr. Prateek Gattani, Mr. Vinay Kothar a/w Ms. Kumkum Shah Mr. Avinash Acharya, Mr. Bhawani Ransi, Mr. Pankaj Arora, Mr. Javed Khan, Mr. Pranjul Mehta, Mr. Manas Ranchhor Khatri For Respondent(s) : Mr. Mukesh Rajpurohit, Dy. SG a/w Ms. Dimple Rajpurohit Mr. K.K. Bissa HON'BLE DR. JUSTICE PUSHPENDRA SINGH BHATI HON'BLE MR. JUSTICE MUNNURI LAXMAN Judgment Reserved on 15/01/2025 Pronounced on 20/03/2025

Per Dr. Pushpendra Singh Bhati, J:

1.

Since the instant petitions involves an identical controversy, therefore, the same are being decided by this common judgment, while taking the prayer clauses, facts and submission from the above-numbered D.B. Civil Writ Petition No.16678/2022, while treating the same as a lead case.

1.1.

The prayer clauses read as under: (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM)

[2025:RJ-JD:5826-DB] (24 of 26) [CW-3270/2023] “It is, therefore, respectfully prayed that this petition for writ preferred by the petitioner may kindly be allowed in toto and the following reliefs may kindly be granted in favour of the petitioner:- A. By an appropriate writ, order or direction, the impugned order under Section 148 A Sub Clause (d) of Income Tax Act, 1961 passed on 29.07.2022 (Annexure- 12) and impugned notice issued under Section 148 on 29.07.2022 (Annexure-13) may kindly be declared illegal and be quashed and set aside. B. By an appropriate writ, order or direction, the proceedings initiated by way of notice dated 22.05.2022 (Annexure-7) for reopening of assessment, reassessment or recomputation may kindly be declared illegal and be quashed and set aside and the respondents may kindly be perpetually restrained to initiate proceedings under Section 147 to 153 of the Income Tax Act, 1961 for the relevant Assessment Year 2013-14 questioning the same. Any other appropriate order or direction, which this Hon’ble Court deems fit and proper may kindly be passed in favor of the petitioner.” (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM)

[2025:RJ-JD:5826-DB] (25 of 26) [CW-3270/2023]

2.

Learned counsel for both the parties, present in the Court, at the time of reserving of the judgment, submitted that they are raising a limited issue of Faceless Assessing Officer viz-a-viz Jurisdictional Assessing Officer and seek to keep rest of the issues open for future adjudication.

3.

This Court observes that the controversy in the present batch of writ petitions concerns the same issue of law as has already been settled by this Court in the case of Sharda Devi Chhajer (supra) regarding the dispute vis-a-vis jurisdiction of Faceless and Jurisdictional Assessing Authority, and therefore, the same settled proposition of law shall govern the field in the instant case as well.

4.

This Court, on the basis of the joint prayers being made and the consensus being arrived at between counsel for the respective parties, observes that all the petitions, which were reserved and are now being disposed of, while treating the Jurisdictional Assessing Officers’ notices illegal. The same are quashed with a liberty to the respondents to proceed via mode of Faceless Assessment in terms of the judgment rendered by this Court in Sharda Devi Chhajer (supra).

5.

The limitation for the period when the petitions have remained pending before this Court shall be excluded for the Faceless Assessing Officer proceedings. In case, there is any issue of Limitation, the Assessing Officer shall be free to decide it in terms of Rajeev Bansal (supra). In case any other issue remains unadjudicated, the parties shall be free to agitate it again before this Court. It is also made clear that any further (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM)

[2025:RJ-JD:5826-DB] (26 of 26) [CW-3270/2023] proceedings under the Faceless Assessment Scheme shall be done strictly in accordance with law. (MUNNURI LAXMAN),J (DR. PUSHPENDRA SINGH BHATI),J SKant/- Powered by TCPDF (www.tcpdf.org) (Uploaded on 21/03/2025 at 03:45:06 PM) (Downloaded on 27/10/2026 at 11:19:55 PM)

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