LATE JWALA PRASAD SARDA vs. ASSISTANT COMMISSIONER OF INCOME TAX

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CW/19641/2025HC Rajasthan27 January 2026Bench: SANJAY K. AGRAWAL, PUSHPENDRA SINGH BHATI27 pages
AI SummaryRemanded

What did the High Court hold?

The Rajasthan High Court, while acknowledging that the core issue concerning Section 153C of the Income Tax Act, 1961, was under adjudication before the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025), decided to extend the same protection granted by the Apex Court to the present writ petitions. The Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP is stated to govern the outcome of these writ petitions. No specific finding was made on the merits of the Section 153C proceedings themselves, as the matter was deferred pending the Apex Court's decision.

What were the facts?

These are multiple writ petitions filed by various individuals, including Pramod Jain, Chandra Prakash Agroya, Pradeep Mittal, Nand Kishore Jain, Arun Choudhary, Tara Chand Goel, and others, against the Assistant Commissioner of Income Tax. The petitioners are challenging notices issued under Section 153C of the Income Tax Act, 1961, and subsequent orders, for Assessment Year 2014-15. The core of the dispute revolves around the initiation of proceedings under Section 153C, which the petitioners argue are without jurisdiction and barred by limitation. The petitions seek to quash these notices and any consequential proceedings or assessment orders.

What were the issues?

1. Whether the initiation of proceedings under Section 153C of the Income Tax Act, 1961, for Assessment Year 2014-15 is without jurisdiction and barred by limitation? Assessee's Contention: The petitioners argue that the proceedings initiated under Section 153C are invalid due to lack of jurisdiction and being time-barred. They seek to quash the notices and any consequential actions taken by the revenue. They rely on the protection granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle, SLP No. 31711/2025, where proceedings under Section 153C were stayed. Revenue's Contention: The respondent revenue authority, represented by the Assistant Commissioner of Income Tax, fairly submits that the order passed by the Hon'ble Apex Court in the aforementioned SLP shall be duly followed. They agree that the present petitions may be disposed of subject to the final outcome of that SLP.

Which sections of the Income-tax Act were involved?

Section 153C

AI-generated summary — verify with the full judgment below

COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 18359/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg Bani Park, Jaipur 302016, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent Connected With D.B. Civil Writ Petition No. 10034/2025 Chandra Prakash Agroya S/o Late Shri Bansi Lal Agroya, Aged About 75 Years, R/o D-46/b, Subhash Marg, C-Scheme, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Circle-04, New Central Revenue Building, Janpath, Jaipur. ----Respondent D.B. Civil Writ Petition No. 10040/2025 Chandra Prakash Agroya S/o Late Shri Bansi Lal Agroya, Aged About 75 Years, Resident Of D-46/b, Subhash Marg, C- Scheme, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income-Tax, Circle-04, New Central Revenue Building, Janpath, Jaipur. ----Respondent D.B. Civil Writ Petition No. 10041/2025 Chandra Prakash Agroya S/o Late Shri Bansi Lal Agroya, Aged About 75 Years, Resident Of D-46/b, Subhash Marg, C- Scheme, Jaipur. ----Petitioner Versus (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(2 of 27) [CW-18359/2025] Assistant Commissioner Of Income-Tax, Circle-04, New Central Revenue Building, Janpath, Jaipur. ----Respondent D.B. Civil Writ Petition No. 12144/2025 Pradeep Mittal, Son Of Shri Anand Shankar Mittal, Aged About 65 Years, Amar Jain Building, Chaura Rasta, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 18756/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg Bani Park, Jaipur 302016, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan- 302005. ----Respondent D.B. Civil Writ Petition No. 18897/2025 Nand Kishore Jain, S/o Late Shri Kapoorchand Jain, Aged About 85 Years, R/o D260, Devi Marg, Bani Park - 302016, Jaipur, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 18908/2025 Nand Kishore Jain, S/o Late Shri Kapoorchand Jain, Aged About 85 Years, R/o D260, Devi Marg, Bani Park - 302016, Jaipur, Rajasthan (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(3 of 27) [CW-18359/2025] ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19380/2025 Arun Choudhary, S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur-302003, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19402/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg, Bani Park, Jaipur 302016, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19403/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg, Bani Park, Jaipur 302016, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(4 of 27) [CW-18359/2025] D.B. Civil Writ Petition No. 19414/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg, Bani Park, Jaipur 302016, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19437/2025 Pramod Jain S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg Bani Park, Jaipur 302016, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19468/2025 Arun Choudhary, S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur-302003, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19469/2025 Arun Choudhary S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur- 302003, Rajasthan. ----Petitioner Versus (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(5 of 27) [CW-18359/2025] Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19473/2025 Arun Choudhary S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur- 302003, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19476/2025 Arun Choudhary S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur- 302003, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19502/2025 Arun Choudhary S/o Bharoon Singh Chaudhary, Aged About 61 Years, R/o 2654, Shah Bhawan, Ghee Walon Ka Rasta, Johari Bazar, Jaipur- 302003, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005. ----Respondent D.B. Civil Writ Petition No. 19637/2025 Tara Chand Goel Son Of Shri Suraj Mal Goel, Aged About 78 (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(6 of 27) [CW-18359/2025] Years, R/o Shubham Enclave, C-Scheme, Jaipur- 302001. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19641/2025 Late Jwala Prasad Sarda, Through Legal Heir Smt Chandra Kanta Sarda, Aged About 68 Years, Wife Of Late Shri Jwala Prasad Sarda, R/o 53, Sangram Colony, C-Scheme, C.p.m.g.s.o, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 19649/2025 Gopal Prasad Gupta, Son Of Shri Bhagwati Prasad Gupta, Aged About 77 Years, 301, Anukampa Mansion - 1, M.i. Road, Jaipur 302001 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 19655/2025 Late Shashi Bilala, Aged About 78 Years, Through Her Legal Heir Shri Surendra Kumar Bilala Son Of Shri Gopi Chand Bilala, R/o 5, Bilala Garden, Old Amer Road, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur, Having Its Address At 4Th Floor Jeevan Nidhi-2 Lic Building Ambedkar Circle Jaipur (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(7 of 27) [CW-18359/2025] ----Respondent D.B. Civil Writ Petition No. 19656/2025 Vimal Chand Surana Son Of Rajmal Surana, Aged About 88 Years, Resident Of B-7, Surana Enclave, Ram Singh Road, Opp. S.m.s. Hospital, Jaipur - 302001 Through His Authorized Signatory Shri Puneet Surana, Aged About 44 Years, S/o Pushpendra Surana, Resident Of B-7, Surana Enclave, Ram Singh Road, Opp. S.m.s. Hospital, Jaipur - 302001 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur, Having Its Address At 4Th Floor Jeevan Nidhi-2 Lic Building Ambedkar Circle Jaipur ----Respondent D.B. Civil Writ Petition No. 19657/2025 Tikam Chand Temani Son Of Shri Nand Kishore Temani, Aged About 63 Years, A-4, Pratap Marg, Sethi Colony, Raja Park, Jaipur- 302004. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19658/2025 Vinay Chand Kothari Son Of Gyan Chand Kothari, Aged About 68 Years, Resident Of 501 Panchratna, 3937 M.s.b. Ka Rasta, Johari Bazar, Jaipur 302003 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur, Having Its Address At 4Th Floor Jeevan Nidhi-2 Lic Building Ambedkar Circle Jaipur ----Respondent D.B. Civil Writ Petition No. 19659/2025 Late Gyan Chand Kothari Through Legal Heir, Shri Vinay Chand Kothari Aged About 68 Years, S/o Late Shri Gyan Chand Kothari, (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(8 of 27) [CW-18359/2025] R/o 101/3, Jawahar Lal Nehru Marg, Near Police Memorial, Jaipur, Currently Residing At 501, Panchratna, 3937 M.s.b. Ka Rasta, Johri Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19834/2025 Bitthal Das Maheswari S/o Late Balkishan Maheshwari, Aged About 76 Years, R/o 57-C, Saraswati Villa, Vishnu Garden, Khokhawas, Tonk Road, Jaipur Rajasthan 302018 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan- 302005 ----Respondent D.B. Civil Writ Petition No. 19840/2025 Bitthal Das Maheswari, S/o Late Balkishan Maheshwari, Aged About 76 Years, R/o 57-C, Saraswati Villa, Vishnu Garden, Khokhawas, Tonk Road, Jaipur, Rajasthan 302018 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19977/2025 Kailash Chand Hirawat S/o Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:56 AM)

(9 of 27) [CW-18359/2025] Circle, Jaipur, Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 19987/2025 Kailash Chand Hirawat S/o Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 19988/2025 Narendra Kumar Nigam S/o Kailash Narayan Nigam, Aged About 76 Years, R/o 704 Fountain Square, Near Jawahar Circle, Malviya Nagar, Jaipur 302017 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19989/2025 Kailash Chand Hirawat S/o Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 19991/2025 Kailash Chand Hirawat S/o, Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(10 of 27) [CW-18359/2025] No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19993/2025 Kailash Chand Hirawat S/o Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 19996/2025 Kailash Chand Hirawat S/o, Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20002/2025 Narendra Kumar Nigam S/o Kailash Narayan Nigam, Aged About 76 Years, R/o 704 Fountain Square, Near Jawahar Circle, Malviya Nagar, Jaipur 302017 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 20011/2025 Kailash Chand Hirawat S/o, Kewal Chand Hirawat, Aged About 86 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner Versus (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(11 of 27) [CW-18359/2025] Assistant Commissioner Of Income Tax, Central Circle - 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20113/2025 Narendra Kumar Nigam S/o Kailash Narayan Nigam, Aged About 76 Years, R/o 704 Fountain Square, Near Jawahar Circle, Malviya Nagar, Jaipur 302017 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 20195/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20204/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20221/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(12 of 27) [CW-18359/2025] Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 20222/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20223/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 20233/2025 Bimla Kumari Hirawat W/o Kailash Chand Hirawat, Aged About 81 Years, R/o 1183, Partanio Ka Rasta, Johari Bazar Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20318/2025 Vijay Kumar Sancheti, S/o Shri Tarachand Sancheti, Aged About 74 Years, R/o D-43 Shubhas Marg, C-Scheme, Jaipur G.p.o. Jaipur, 302001, Rajasthan. (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(13 of 27) [CW-18359/2025] ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20319/2025 Vijay Kumar Sancheti, S/o Shri Tarachand Sancheti, Aged About 74 Years, R/o D-43 Shubhas Marg, C-Scheme, Jaipur G.p.o. Jaipur, 302001, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20320/2025 Vijay Kumar Sancheti, S/o Shri Tarachand Sancheti, Aged About 74 Years, R/o D-43 Shubhas Marg, C-Scheme, Jaipur G.p.o. Jaipur, 302001, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20321/2025 Vijay Kumar Sancheti, S/o Shri Tarachand Sancheti, Aged About 74 Years, R/o D-43 Shubhas Marg, C-Scheme, Jaipur G.p.o. Jaipur, 302001, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(14 of 27) [CW-18359/2025] D.B. Civil Writ Petition No. 20323/2025 Vijay Kumar Sancheti, S/o Shri Tarachand Sancheti, Aged About 74 Years, R/o D-43 Shubhas Marg, C-Scheme, Jaipur G.p.o. Jaipur, 302001, Rajasthan. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 21188/2019 Abhay Chordia, S/o Shri Ashok Kumar Jain, Aged About 37 Years, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Circle -2, New Central Revenue Building, Bhagwan Das Road, Jaipur-302005 ----Respondent D.B. Civil Writ Petition No. 14117/2022 Abhay Chordia, S/o Shri Ashok Kumar Jain, Aged About 40 Years, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus 1. Deputy Commissioner Of Income Tax, Central Circle 4, Ncr Building, Jaipur 2. Union Of India, Through Finance Secretary, Ministry Of Finance (Department Of Revenue), Central Board Of Direct Taxes, North Block, New Delhi 110002 ----Respondents D.B. Civil Writ Petition No. 14118/2022 Abhay Chordia, S/o Shri Ashok Kumar Jain, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Deputy Commissioner Of Income Tax, Central Circle 4, Ncr Building, Jaipur (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(15 of 27) [CW-18359/2025] ----Respondent D.B. Civil Writ Petition No. 10032/2025 Chandra Prakash Agroya, S/o Late Shri Bansi Lal Agroya, Aged About 75 Years, Resident Of D-46/b, Subhash Marg, C-Scheme, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Circle-04, New Central Revenue Building, Janpath, Jaipur. ----Respondent D.B. Civil Writ Petition No. 10033/2025 Chandra Prakash Agroya S/o Late Shri Bansi Lal Agroya, Aged About 75 Years, R/o D-46/b, Subhash Marg, C-Scheme, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income- Tax, Circle-04, New Central Revenue Building, Janpath, Jaipur. ----Respondent D.B. Civil Writ Petition No. 11451/2025 Ganpat Singh Karnawat Son Of Shri Fateh Singh Karnawat, Aged About 82 Years, 4812 Karnawat Bhawan K.g.b. Ka Rasta, Johari Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor Jeevan Nidhi-2 Lic Building Ambedkar Circle Jaipur ----Respondent D.B. Civil Writ Petition No. 11535/2025 Nishit Gupta Son Of Shri Ramesh Chand Gupta, Aged About 57 Years, Resident Of B-73, Janta Colony, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(16 of 27) [CW-18359/2025] ----Respondent D.B. Civil Writ Petition No. 11922/2025 Jitendra Kumar Daga Son Of Shri Vimal Chand Daga, Aged About 55 Years, 1370, Tara Chand Naib Ka Rasta, Johari Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 12495/2025 Abhay Chordia, S/o Shri Ashok Chordia, Aged About 43 Years, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 12574/2025 Prashant Gupta S/o Shri Gopal Prasad Gupta, Aged About 50 Years, R/o 301, Anukampa Mansion, M.i. Road, Jaipur, Rajasthan- 302001. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 12640/2025 Abhay Chordia S/o Shri Ashok Chordia, Aged About 43 Years, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(17 of 27) [CW-18359/2025] Circle, Jaipur Rajasthan- 302005 ----Respondent D.B. Civil Writ Petition No. 12752/2025 Prashant Gupta S/o Shri Gopal Prasad Gupta, Aged About 50 Years, R/o 301, Anukampa Mansion, M.i. Road, Jaipur, Rajasthan- 302001. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan- 302005. ----Respondent D.B. Civil Writ Petition No. 12770/2025 Prashant Gupta S/o Shri Gopal Prasad Gupta, Aged About 50 Years, R/o 301, Anukampa Mansion, M.i. Road, Jaipur, Rajasthan- 302001. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur Rajasthan-302005 ----Respondent D.B. Civil Writ Petition No. 12809/2025 Abhay Chordia S/o Shri Ashok Chordia, Aged About 43 Years, R/o 4459, Kgb Ka Rasta, Johari Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Room No. 416, 4Th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan- 302005. ----Respondent D.B. Civil Writ Petition No. 13588/2025 Rajesh Kumar Dhaddha Son Of Shri Gyan Chand Dhaddha, Aged About 59 Years, Gems Paradise, Gulab Niwas, M.i. Road, Jaipur 302001 ----Petitioner (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(18 of 27) [CW-18359/2025] Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur, Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 18764/2025 Pramod Jain, S/o Nand Kishore Jain, Aged About 62 Years, Residing At D260, Devi Marg Bani Park, Jaipur 302016, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle- 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 18947/2025 Nand Kishore Jain, S/o Late Shri Kapoorchand Jain, Aged About 85 Years, R/o D260, Devi Marg, Bani Park - 302016, Jaipur, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 18949/2025 Nand Kishore Jain, S/o Late Shri Kapoorchand Jain, Aged About 84 Years, R/o D260, Devi Marg, Bani Park - 302016, Jaipur, Rajasthan ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19638/2025 (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(19 of 27) [CW-18359/2025] Devendra Kumar Temani Son Of Shri Nand Kishore Temani, Aged About 57 Years, 313, Surya Chamber, Near Nehru Bazar, Jaipur 302003. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19639/2025 Vimal Parwal Son Of Shri Kailash Chand Parwal, Aged About 52 Years, C-175A, Gyan Marg, Tilak Nagar, Jaipur 302016. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19651/2025 Alka Kotawala Daughter Of Ram Sharan Agarwal, Aged About 50 Years, Resident Of C-143, Mahavir Marg, Malviya Nagar, Jaipur- 302017 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19653/2025 Manju Seth Daughter Of Shri Gyan Chand Kothari, Aged About 57 Years, 3-Ta, 56 A Jawahar Nagar, Arjun Lal Sethi Nagar, Jaipur 302004 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur, Having Its Address At 4Th Floor Jeevan Nidhi-2 Lic Building (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(20 of 27) [CW-18359/2025] Ambedkar Circle Jaipur ----Respondent D.B. Civil Writ Petition No. 19660/2025 Pallavi Sethi, Daughter Of Shri Mahabir Prasad Patni, Aged About 50 Years, R/o 417, Sethi Bhawan, Hanuman Ji Ka Rasta, Johri Bazar, Jaipur 302003 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 19662/2025 Late Dr. Damodar Prasad Parwal, Through His Legal Heir Mr. Navin Kumar Parwal Aged About 55 Years, Son Of Late Dr. Damodar Prasad Parwal, R/o Plot No. 24, Sangram Colony, C- Scheme, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 19663/2025 Late Sh. Kishan Singh Karnawat, Through His Legal Heir Sh. Jitendra Singh Karnawat Aged About 56 Years, Son Of Late Sh. Kishan Singh Karnawat, R/o A-3, Vijay Path, Tilak Nagar, Jaipur ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur ----Respondent D.B. Civil Writ Petition No. 19984/2025 Manoj Kumar Dhandia S/o Late Shri Mehar Chand Dhandia, Aged About 58 Years, R/o 3958, Kgb Ka Rasta, Johari Bazar, Jaipur (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(21 of 27) [CW-18359/2025] 302003 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 19986/2025 Manoj Kumar Dhandia S/o, Late Shri Mehar Chand Dhandia, Aged About 58 Years, R/o 3958, Kgb Ka Rasta, Johari Bazar, Jaipur 302003 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 19990/2025 Manoj Kumar Dhandia S/o Late Shri Mehar Chand Dhandia, Aged About 58 Years, R/o 3958, Kgb Ka Rasta, Johari Bazar, Jaipur 302003 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent D.B. Civil Writ Petition No. 20349/2025 Rajendra Kumar Mundra Son Of Shrikrishn Mundra, Aged About 74 Years, 74, Sangram Colony, C-Scheme, Jaipur 302001 ----Petitioner Versus 1. Assistant Commissioner Of Income Tax, Central Circle, Alwar Having Its Address At 1St Floor, New Admin Bsnl Building, Opp. Cr Building, Moti Dungri Circle, Alwar. 2. Assistant Commissioner Of Income Tax, Central Circle-4, (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(22 of 27) [CW-18359/2025] Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondents D.B. Civil Writ Petition No. 20902/2025 Late Prakash Chand Daga Through L/h Shri Virendra Kumar Daga, Aged About 58 Years, S/o Late Shri Prakash Chand Daga, R/o 1482, Barah Gangore Ka Rasta, Johri Bazar, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 229/2026 Abhay Kumar Baid Son Of Santosh Chand Baid, Aged About 57 Years, Resident Of 20, Burmise Colony, Jaipur 302004 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 475/2026 Vipin Totla Son Of Babu Lal Totla, Aged About 58 Years, Resident Of Somani Building, Loha Mandi, S.c. Link Road, Jaipur-302001 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 1050/2026 Ashok Parwal (Ay 2012-13) S/o Shri Radhey Shyam Parwal, Aged About 59 Years, R/o M-57, Mahesh Colony, Tonk Phatak, Lal Kothi, Jaipur, Rajasthan- 302015 (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(23 of 27) [CW-18359/2025] ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan ----Respondent D.B. Civil Writ Petition No. 19729/2025 Yogesh Kumar Khatoria Son Of Radhey Shyam Khatoria, Aged About 55 Years, Resident Of 208, Balaji Ka Rasta, Ghat Gate, Jaipur- 302005. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur. ----Respondent D.B. Civil Writ Petition No. 19746/2025 Bitthal Das Maheswari, S/o Late Balkishan Maheshwari, Aged About 76 Years, R/o 57-C, Saraswati Villa, Vishnu Garden, Khokhawas, Tonk Road, Jaipur, Rajasthan 302018 ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 19778/2025 Bitthal Das Maheswari, S/o Late Balkishan Maheshwari, Aged About 76 Years, R/o 57-C, Saraswati Villa, Vishnu Garden, Khokhawas, Tonk Road, Jaipur, Rajasthan 302018 ----Petitioner Versus (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(24 of 27) [CW-18359/2025] Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan - 302005 ----Respondent D.B. Civil Writ Petition No. 18765/2025 Nand Kishore Jain S/o Late Shri Kapoorchand Jain, Aged About 85 Years, R/o D260, Devi Marg, Bani Park, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle -4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambdekar Circle, Jaipur, Rajasthan ----Respondent D.B. Civil Writ Petition No. 18943/2025 Nand Kishore Jain, S/o Late Shri Kapoorchand Jain, Aged About 85 Years, R/o D260, Devi Marg, Bani Park, Jaipur. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle - 4, Room No. 416, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005 ----Respondent For Petitioner(s) : Mr. Sanjay Jhanwar, Sr. Advocate assisted by Mr. Prakul Khurana, Mr. Rajat Sharma, Mr. Shubhendra Singh, Mr. Saksham Pandey, Mr. Akshay Sharma Mr. Dileep Shivpuri, Mr. Utkarsh Shara Mr. Siddharth Ranka Ms. Gunjan Pathak with Ms. Neha Pathak, Mr. Kanishk Singhal, Mr. Aditya Bohra, Ms. Ishita Rawat, Ms. Priyanshi Roongta Mr. Dheeraj Kumar Palia Ms. Pratyushi Mehta for Mr. Vedant Agarwal (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(25 of 27) [CW-18359/2025] For Respondent(s) : Mr. Siddharth Bapna with Ms. Tanushka Saxena HON'BLE DR. JUSTICE PUSHPENDRA SINGH BHATI HON'BLE MRS. JUSTICE SANGEETA SHARMA Order 27/01/2026 1. These writ petitions under Article 226 of the Constitution of India have been filed, in substance, seeking identical reliefs. For the sake of convenience, the prayer clause is extracted from D.B. Civil Writ Petition No. 18359/2025, which reads as under: “1. Issue writ in the nature of certiorari or any other appropriate writ, Order or direction to the effect declaring the initiation of proceedings under Section 153C for AY 2014-15 to be without jurisdiction and barred by limitation and accordingly quashing the Notice dated 28.01.2025 issued under Section 153C of the Act. 2. Issue writ in the nature of certiorari or any other appropriate writ, Order or direction to the effect Quashing the Objection Disposal Order dated 06.10.2025. 3. Issue writ in the nature of certiorari or any other appropriate writ, Order or direction to the effect Quashing any consequential proceedings, Assessment Orders if any passed during the pendency of the present writ petition. 4. Pass such other and further order as may be deemed just and proper in the facts and circumstances of the case.” 2. Learned counsel for the petitioners submits that the controversy involved in the present matters is under consideration (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(26 of 27) [CW-18359/2025] before the Hon’ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle in SLP No. 31711/2025, in which the following order was passed on 08.12.2025: “1. Issue notice. 2. Dasti service, in addition, is permitted. 3. Tag with SLP(C) No. 33392 of 2025. 4. In the meantime, the proceedings before the Adjudicating Authority shall remain stayed insofar as Section 153C of the Income Tax Act, 1961 is concerned including the order impugned passed by the High Court.” 3. Learned counsel for the petitioners submits that the proceedings before the Adjudicating Authority, insofar as they pertain to Section 153C of the Income Tax Act, 1961, including the impugned order under consideration before this Hon’ble Court in the present case, have been stayed by the Hon’ble Apex Court. It is, therefore, prayed that similar protection be extended in the present petitions as well. Learned counsel further fairly submits that the outcome of these petitions shall be governed by the outcome of the said SLP and, thus, subject to such outcome, the petitions may be disposed of while extending the aforesaid protection. 4. Learned counsel for the respondents fairly submits that the order passed by the Hon’ble Apex Court shall be duly followed. He further submits that in the event these petitions are disposed of, the same may be made subject to the final outcome of the aforesaid SLP. (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

(27 of 27) [CW-18359/2025] 5. Having considered the submissions made at the Bar, this Court is of the clear opinion that once the narrow compass of the issue is being directly adjudicated by the Hon’ble Apex Court in pursuance of the litigation undergone by the parties pertaining to Section 153C of the Income Tax Act, 1961, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon’ble Apex Court. 6. Accordingly, it is directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961 against the petitioners, as also consequential order(s), if any, including giving effect to any impugned orders, for so long as the interim protection granted by the Hon’ble Apex Court continues to operate. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. 7. The instant writ petitions are disposed of accordingly. 8. Pending application(s), if any, shall also stand disposed of. 9. A copy of this order be placed in each file. (SANGEETA SHARMA),J (DR.PUSHPENDRA SINGH BHATI),J 10-90, 101, 92, 132, 133, 151 & 183-Nirmala/Shivani Powered by TCPDF (www.tcpdf.org) (Uploaded on 31/01/2026 at 02:30:09 PM) (Downloaded on 30/10/2026 at 10:20:57 AM)

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