Rajasthan High Court Judgments — 2025

The High Court held that the Income Tax Appellate Tribunal (ITAT) was not justified in deciding the case on merits when the Commissioner (Appeals) had dismissed the appeal on technical grounds. Citing the precedent in *Prem Agencies vs. Commissioner of Income Tax*, the Court reasoned that if the ITAT concludes that the dismissal by the Commissioner (Appeals) was incorrect, the matter should be remanded to the Commissioner (Appeals) to decide the appeal on merits. The High Court quashed and set aside the ITAT's order to the extent it decided the case on merits. The matter was remanded to the Commissioner (Appeals) to decide the second question of law regarding the market value of electricity. All rights and contentions of the parties on merits were kept open. The Commissioner (Appeals) was directed to dispose of the appeal on or before October 31, 2025.

The Tribunal quashed and set aside the notice dated 20.04.2023 issued under Section 148 of the Income Tax Act, 1961. The decision was based on the established legal position that such notices should be issued by Faceless Assessing Officers (FAO) and not by Jurisdictional Assessing Officers (JAO), as supported by the cited precedents. The Tribunal granted liberty to the Revenue to revive the notice if the Supreme Court were to interfere with the judgments in Hexaware Technologies Ltd., Sharda Devi Chhajer, or Shree Cement Limited. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with this liberty granted to the revenue.

The Tribunal quashed and set aside the notice dated 13.04.2023 issued under Section 148 of the Income Tax Act, 1961. The decision was based on the established legal position that such notices should be issued by the Faceless Assessing Officer (FAO) and not the Jurisdictional Assessing Officer (JAO), as supported by the precedents in Hexaware Technologies Ltd., Sharda Devi Chhajer, and Shree Cement Limited. The Tribunal granted the revenue liberty to revive the notice if the Supreme Court were to interfere with these judgments. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with these directions, keeping open all rights and contentions of the parties.

The Tribunal quashed and set aside the notice dated 12.04.2023 issued under Section 148 of the Income Tax Act, 1961. The decision was based on the established principle that such notices must be issued by the Faceless Assessing Officer (FAO) and not the Jurisdictional Assessing Officer (JAO), as supported by the cited High Court judgments. The Tribunal granted liberty to the revenue to revive the notice if the Supreme Court were to alter the legal position established in the aforementioned precedents. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with these directions, and all pending applications were also disposed of.

The Tribunal quashed and set aside the notice dated April 17, 2023, issued under Section 148 of the Income Tax Act, 1961. The decision was based on the petitioner's primary ground that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), a point supported by various High Court judgments. The Tribunal granted the revenue liberty to revive the notice if the Supreme Court were to interfere with the precedents relied upon by the petitioner, namely Hexaware Technologies Ltd., Sharda Devi Chhajer, and Shree Cement Limited. The Tribunal clarified that the petitioner did not press other grounds. The petition was disposed of, keeping open all rights and contentions of the parties.

The Tribunal quashed and set aside the notice dated 10.04.2023 issued under Section 148 of the Income Tax Act, 1961. The decision was based on the petitioner's primary ground that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO). The Tribunal relied on the precedents established in Hexaware Technologies Ltd. Vs. Assistant Commissioner of Income-tax, Circle 15(1)(2), Sharda Devi Chhajer Vs. The Income Tax Officer & Another, and Shree Cement Limited Vs. Assistant Commissioner of Income-Tax & Others. The Tribunal granted liberty to the revenue to revive the notice if the Apex Court were to interfere with the aforementioned judgments. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with this liberty granted to the revenue.

The Tribunal quashed and set aside the notice dated 12.04.2023 issued under Section 148 of the Income Tax Act, 1961. The primary reason for this decision was that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO), which was found to be contrary to the established legal position as discussed in the cited precedents. The Tribunal acknowledged the petitioner's submission that this issue had been extensively dealt with in Hexaware Technologies Ltd., Sharda Devi Chhajer, and Shree Cement Limited. The revenue did not dispute the factual aspect of the notice being issued by the JAO. The Tribunal granted liberty to the revenue to revive the notice if the Supreme Court were to alter the judgments relied upon by the petitioner. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with these directions.

The Rajasthan High Court at Jodhpur quashed and set aside the notice dated 16.04.2023 issued under Section 148 of the Income Tax Act, 1961. The Court followed the precedent set in Hexaware Technologies Ltd. vs. Assistant Commissioner of Income-tax, Circle 15(1)(2), Sharda Devi Chhajer vs. The Income Tax Officer & Another, and Shree Cement Limited vs. Assistant Commissioner of Income-Tax & Others, which dealt with the validity of notices issued by JAOs instead of FAOs. The Court granted the revenue liberty to revive the notice issued under Section 148 if the Apex Court were to interfere with the judgments in the aforementioned cases. The Court also clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with these directions.

The High Court re-framed the substantial question of law to focus on whether the Tribunal erred in allowing loss in non-speculative business to be set off against income from speculative business, considering the limitations under Sections 70, 72, and 73. The Tribunal, relying on the ITAT Lucknow decision in Ramshree Steels (P) Ltd. Vs. Income Tax Officer and the Allahabad High Court's confirmation in Commissioner of Income Tax Vs. Ramshree Steels (P) Ltd., held in favour of the assessee. The Allahabad High Court had concluded that brought forward and current business loss of non-speculative business is liable to be set off against current profits of speculative business. The Rajasthan High Court respectfully agreed with the findings of the Allahabad High Court. Therefore, the substantial question of law was answered in favour of the assessee, and the ITAT's conclusion was upheld. The appeal was dismissed.

The Tribunal quashed and set aside the notice dated 17.04.2023 issued under Section 148 of the Income Tax Act, 1961. The primary reasoning was based on the petitioner's submission that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), which was supported by several High Court judgments, including Hexaware Technologies Ltd., Sharda Devi Chhajer, and Shree Cement Limited. The Tribunal acknowledged the Revenue's submission regarding the pending Special Leave Petition before the Apex Court in the Hexaware Technologies case and granted liberty to the Revenue to revive the notice if the Apex Court's decision differed from the cited High Court judgments. The Tribunal clarified that the petitioner did not press other grounds raised in the petition. The petition was disposed of with these directions.

The Tribunal quashed and set aside the notice dated 12.04.2023 issued under Section 148 of the Income Tax Act, 1961. The reasoning was based on the established legal position, as discussed in the cited cases of Hexaware Technologies Ltd., Sharda Devi Chhajer, and Shree Cement Limited, which held that notices under Section 148 should be issued by the Faceless Assessing Officer (FAO) and not the Jurisdictional Assessing Officer (JAO). The Tribunal granted the petitioner's prayer, quashing the notice. However, in deference to the revenue's submission, the Tribunal kept open all rights and contentions of both parties and granted the revenue liberty to revive the notice if the Supreme Court were to interfere with the aforementioned judgments. The Tribunal also noted that the petitioner did not press other grounds raised in the petition. The petition was disposed of accordingly.

The Tribunal quashed and set aside the notice dated 24.04.2023 issued under Section 148 of the Income Tax Act, 1961. The decision was based on the petitioner's primary ground that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), a contention supported by the cited High Court judgments. The Tribunal granted liberty to the revenue to revive the notice if the Apex Court were to overturn the decisions in Hexaware Technologies Ltd., Sharda Devi Chhajer, or Shree Cement Limited, thereby keeping open all rights and contentions of the parties. The Tribunal also clarified that the petitioner did not press other grounds raised in the petition. The operative direction was to quash the notice with liberty to revive, and the petition was disposed of.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them, even under the new faceless regime. This decision was based on the Supreme Court's exercise of power under Article 142 in Ashish Aggarwal's case, which provided jurisdiction to the JAO by a deemed fiction of law. The Court reasoned that if an allegation of escaped income led to notices being issued by the JAO, these must reach a logical conclusion by the same officer. The JAO would, however, need to follow the procedure laid down under the new regime. The Court found no prejudice in this course of action and rejected the petitioners' submissions. It also distinguished the cases of Kankanala Ravindra Reddy, Jasjit Singh, and Hexaware Technologies Limited, finding them not applicable to the present bunch of cases. The Court directed the revenue to examine each case individually concerning deemed notices issued under Section 148, in light of the Supreme Court's observations in Rajeev Bansal's case, particularly regarding limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court noted that appeals against final assessment orders would be decided in view of these findings. Any aggrieved petitioner could avail remedies under the Act.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even after the introduction of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO, which was treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO, and no prejudice would be caused to the petitioners by this course of action. The Court explicitly disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping proceedings. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of Rajeev Bansal's case. The Court ordered accordingly, disposing of all petitions.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them, even in the context of the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that if the initial notice was issued by the JAO and treated as a notice under Section 148A, the JAO is the appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and no prejudice would be caused to the petitioners. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court clarified that for cases where appeals against final assessment orders were filed, those appeals would be decided in view of the observations and findings herein. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. This exercise was to be completed expeditiously, preferably within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment. All petitions were disposed of accordingly, with the option for assessees to avail remedies under the Act if aggrieved by subsequent orders.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by him, even after the introduction of the faceless regime. The Court reasoned that no prejudice would be caused by this course of action and that the JAO is the best person to assess and re-assess the provisions of law. The Court explicitly disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-barred proceedings. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Supreme Court. The exercise was to be conducted expeditiously, preferably within two months, and decisions conveyed to the assessees under the faceless regime. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah disposed of SLPs in terms of Rajeev Bansal's case. Any aggrieved party could avail remedies under the Act. Appeals against final assessment orders were to be decided in view of the findings.

The High Court held that the jurisdictional assessing officer (JAO) retains jurisdiction to proceed with notices originally issued by them, even under the new faceless regime. The court reasoned that the initial notice was issued by the JAO, and this should be treated as a notice under Section 148A and Section 148 of the Act. The court emphasized that the procedure laid down under the new regime must be followed by the JAO, and no prejudice would be caused by this course of action. The court disagreed with the Telangana High Court's view in Kankanala Ravindra Reddy's case and found the petitioners' contentions to be without force. The court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-barring provisions. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Supreme Court. The exercise was to be completed expeditiously, preferably within two months, and decisions conveyed under the faceless regime. Appeals against final assessment orders would be decided based on these findings.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by him, even under the new faceless regime. The Court reasoned that the procedure laid down under the new regime would have to be followed by the JAO, and no prejudice would be caused to the assessee by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submission regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court clarified that its own judgment in Jasjit Singh's case dealt with notices issued after the faceless regime came into force. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions. Cases below Rs. 50,00,000/- were to be dropped, as per the revenue's stand before the Supreme Court. The exercise was to be conducted expeditiously, and the decision conveyed to the assessee under the faceless regime. The Court noted that the Supreme Court had also disposed of SLPs in terms of the Rajeev Bansal judgment in related cases. All petitions were disposed of with liberty to the assessee to avail remedies under the Act if aggrieved by subsequent orders.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by him, even if they were deemed to be under Section 148A and Section 148 of the Act. The Court reasoned that the initial notice was issued by the JAO, and it would be logical for him to conclude the proceedings. The Court clarified that the procedure laid down under the new faceless regime would have to be followed by the JAO, and no prejudice would be caused to the assessees by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the dropping of cases below Rs. 50,00,000/-. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. The Court did not expressly leave any issue undecided.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to issue notices under Section 148A and Section 148 of the Income Tax Act, 1961, and to proceed with reassessment proceedings, even after the introduction of the faceless regime. The Court reasoned that the initial notice was issued by the JAO and was treated as a notice under Section 148A and Section 148 of the Act. Therefore, the JAO is the appropriate authority to assess and re-assess the provisions of law. The Court emphasized that the procedure laid down under the new regime must be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-barring provisions. Cases below Rs. 50,00,000/- are to be dropped based on the revenue's stand before the Supreme Court. The exercise is to be completed expeditiously within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah disposed of SLPs in terms of Rajeev Bansal's judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by him, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The initial notice was treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also stated that the procedure laid down under the new regime will have to be followed by the JAO, and no prejudice would be caused by this approach. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions, and to drop cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. This exercise is to be completed expeditiously within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of Rajeev Bansal's case. All petitions were disposed of accordingly, with liberty to the assessee to avail remedies under the Act if aggrieved by the final order.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by him, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The initial notice was treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also stated that the procedure laid down under the new regime will have to be followed by the JAO, and no prejudice would be caused by this approach. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions, and to drop cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. This exercise is to be completed expeditiously within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of Rajeev Bansal's case. All petitions were disposed of accordingly, with liberty to the assessee to avail remedies under the Act if aggrieved by the final order.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to issue notices under Section 148A and proceed with reassessment under Section 148 of the Income Tax Act, 1961, even after the introduction of the faceless regime, provided the initial notice was issued by the JAO. The Court found that no prejudice would be caused by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering the limitation period and the revenue's stand before the Supreme Court regarding cases below Rs. 50,00,000/-. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that subsequent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah had disposed of SLPs in terms of Rajeev Bansal's case. For cases where final assessment orders were passed and appeals were filed, those appeals would be decided in view of the findings in the present judgment. The writ petitions were disposed of accordingly, with liberty to the assessees to avail remedies under the Act if still aggrieved.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even if they were deemed to be under Section 148A and Section 148 of the Act. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under the new faceless regime by a deemed fiction of law. The Court found no prejudice in this course of action and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case. The Court also distinguished its own prior decision in Jasjit Singh's case, noting that it dealt with notices issued after the faceless regime came into force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation periods and dropping cases below Rs. 50,00,000/-. The Court also noted that appeals against final assessment orders would be decided based on the findings in these writ petitions. Any aggrieved petitioner could avail remedies under the Act. The Court explicitly stated that contentions raised before it were rejected.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even if they were deemed to be under Section 148A and Section 148 of the Act. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under the new faceless regime by a deemed fiction of law. The Court found no prejudice in this course of action and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case. The Court also distinguished its own prior decision in Jasjit Singh's case, noting that it dealt with notices issued after the faceless regime came into force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation periods and dropping cases below Rs. 50,00,000/-. The Court also noted that appeals against final assessment orders would be decided based on the findings in these writ petitions. Any aggrieved petitioner could avail remedies under the Act. The Court explicitly stated that contentions raised before it were rejected.

The High Court held that the jurisdictional Assessing Officer (AO) would continue to have jurisdiction to decide notices that were originally issued by him, even in cases where the faceless regime has been introduced. The Court reasoned that the initial notice was issued by the jurisdictional AO, and this notice was treated as a notice under Section 148A and Section 148 of the Act. Therefore, the AO who issued the notice is best placed to assess and re-assess the provisions of law. The Court emphasized that the procedure laid down under the new regime will have to be followed by the jurisdictional AO, and no prejudice would be caused by adopting this course. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' contentions to be without force. The Court also clarified that the judgment in Jasjit Singh's case was factually different as it dealt with notices issued after the faceless regime came into force. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, including the limitation period and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah disposed of SLPs in terms of Rajeev Bansal's case. If assessees are aggrieved by the final assessment order, they can avail the remedy of appeal.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO under the new faceless regime by a deemed fiction of law. The initial notice was treated as a notice under Section 148A, and the JAO, being the original issuer, is best placed to assess and re-assess. The Court found no prejudice in this course of action and disagreed with the Telangana High Court's view in Kankanala Ravindra Reddy's case. The Tribunal also rejected contentions regarding the non-application of the Rajeev Bansal case. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The exercise was to be completed expeditiously, preferably within two months. Appeals against final assessment orders were to be decided in view of the findings.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO under the new faceless regime by a deemed fiction of law. The initial notice was treated as a notice under Section 148A, and the JAO, being the original issuer, is best placed to assess and re-assess. The Court found no prejudice in this course of action and disagreed with the Telangana High Court's view in Kankanala Ravindra Reddy's case. The Tribunal also rejected contentions regarding the non-application of the Rajeev Bansal case. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The exercise was to be completed expeditiously, preferably within two months. Appeals against final assessment orders were to be decided in view of the findings.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had provided jurisdiction to the JAO by a deemed fiction of law. The Court found that the initial notice was issued by the JAO and was treated as a notice under Section 148A, thus the JAO was the appropriate authority to proceed. The Court stated that the procedure laid down under the new regime would have to be followed by the JAO and no prejudice would be caused to the assessees. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions, and to drop cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The exercise was to be completed within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, had specifically provided for the jurisdiction of the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also noted that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. Consequently, the Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. All writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide the notices that were originally issued by him. The Court reasoned that the initial notice was issued by the JAO, which was treated as a notice under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed to assess and re-assess the provisions of law. The Court emphasized that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-barring provisions. Cases below Rs. 50,00,000/- were to be dropped, adhering to the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months, and communicated to the assessee under the faceless regime. The Court noted that appeals against final assessment orders would be decided in view of these findings.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its powers under Article 142 in Ashish Aggarwal's case, provided jurisdiction to the JAO by a deemed fiction of law. The initial notice issued by the JAO, treated as a notice under Section 148A, should logically be concluded by the same officer. The Court found no prejudice in this course of action and rejected the petitioners' submissions. It also clarified that the procedure laid down under the new regime must be followed by the JAO. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitation periods and the value of escaped income (cases below Rs. 50,00,000/- to be dropped). This exercise was to be completed expeditiously, preferably within two months. The Court also noted recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah, which disposed of SLPs in terms of Rajeev Bansal's judgment. All petitions were disposed of accordingly, with liberty to the aggrieved parties to avail remedies under the Act.

The High Court held that the jurisdictional Assessing Officer (AO) would continue to have jurisdiction to decide notices that were originally issued by him, even in cases involving the transition to the faceless regime. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, provided for the jurisdiction of the jurisdictional AO by deemed fiction of law under the new faceless regime. Therefore, the AO who initially issued the notice is best placed to assess and re-assess the provisions of law. The Court directed that the procedure laid down under the new regime, including Section 144-B, must be followed by the AO. No prejudice would be caused by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' contention regarding the non-application of Rajeev Bansal's case to be misconceived. The Court also directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and dropping cases below Rs. 50,00,000/-. Appeals against final assessment orders were to be decided in view of these findings. The writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even if they were deemed to be under Section 148A and Section 148 of the Income Tax Act, 1961, under the new faceless regime. The Court reasoned that no prejudice would be caused to the assessees by this course of action and that the procedure laid down under the new regime would have to be followed by the JAO. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court directed the revenue to examine each case relating to deemed notices under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Supreme Court. The exercise was to be completed expeditiously, preferably within two months, and conveyed to the assessee under the faceless regime. The Court also noted that subsequent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah disposed of SLPs in terms of Rajeev Bansal's judgment. The writ petitions were disposed of accordingly, with the option for assessees to avail remedies under the Act if aggrieved by the final order.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings that were originally initiated by them, even during the transition to the faceless assessment regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO, which was treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the most appropriate authority to assess and re-assess. The Court also directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering the limitation periods and dropping cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The Court explicitly rejected the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and distinguished its own prior decision in Jasjit Singh's case. The Court also noted that appeals against final assessment orders would be decided based on these findings. The operative direction is for the concerned officer to conduct the exercise expeditiously, preferably within two months, and convey the decision to the assessee.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings that were originally initiated by them, even during the transition to the faceless assessment regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO, which was treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the most appropriate authority to assess and re-assess. The Court also directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering the limitation periods and dropping cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The Court explicitly rejected the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and distinguished its own prior decision in Jasjit Singh's case. The Court also noted that appeals against final assessment orders would be decided based on these findings. The operative direction is for the concerned officer to conduct the exercise expeditiously, preferably within two months, and convey the decision to the assessee.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them, even if these notices were issued after the introduction of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO under the new faceless regime by a deemed fiction of law. The Court found that the initial notices were issued by the JAO and treated as notices under Section 148A and Section 148 of the Act, and therefore, the JAO is the most appropriate authority to assess and re-assess. The Court also directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and cases below Rs. 50,00,000/- which should be dropped. The Court explicitly disagreed with the Telangana High Court's view in Kankanala Ravindra Reddy's case and distinguished its own judgment in Jasjit Singh's case. The Court also noted that appeals against final assessment orders would be decided based on these findings. The petitioners' contentions were rejected, and the writ petitions were disposed of.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to issue notices under Section 148A and proceed with reassessment under Section 148 of the Income Tax Act, 1961, in cases where the initial notice was issued by the JAO prior to the full implementation of the faceless regime. The Court reasoned that by a deemed fiction of law, the JAO has jurisdiction under the new faceless regime. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning the limitation period and the threshold of Rs. 50,00,000/- for dropping proceedings. The Court clarified that the procedure laid down under the new regime must be followed by the JAO and that no prejudice would be caused. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the contention regarding non-application of Rajeev Bansal's case to be misconceived. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. The ratio is that the JAO's jurisdiction is preserved for pre-faceless regime initiated notices, subject to adherence to new procedures and Supreme Court directives.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by them, despite the introduction of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, specifically provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act, making the JAO the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO, and no prejudice would be caused to the assessees by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' submissions to be without force. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar provisions, and to drop cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment. All petitions were disposed of accordingly, with liberty to the aggrieved parties to avail remedies under the Act.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings initiated by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, provided for the jurisdiction of the JAO by deemed fiction of law under the new regime. Therefore, notices initially issued by the JAO, treated as notices under Section 148A and Section 148, must reach their logical conclusion by the same officer. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, particularly concerning limitation and time-barred proceedings. Cases with an income escape of less than Rs. 50,00,000/- are to be dropped, as per the revenue's stand before the Supreme Court. The exercise is to be completed expeditiously, preferably within two months, and the decision conveyed to the assessee under the faceless regime. The Court also noted that subsequent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah also disposed of SLPs in terms of Rajeev Bansal's judgment. The Tribunal rejected the contentions raised by the petitioners and disposed of all petitions.

The High Court held that the jurisdictional Assessing Officer (AO) would continue to have jurisdiction to decide notices that were originally issued by them, even in the context of the new faceless regime. The Court reasoned that no prejudice would be caused by this course of action and that the AO, being the original issuer of the notice, is best placed to assess and re-assess the provisions of law. The Court explicitly disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court clarified that its own decision in Jasjit Singh's case was factually different as it dealt with notices issued after the faceless regime came into force. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-barring provisions. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Supreme Court. The exercise was to be completed expeditiously, preferably within two months, and decisions conveyed to assessees under the faceless regime. The Court also noted recent Supreme Court judgments disposing of SLPs in terms of Rajeev Bansal's case. Appeals against final assessment orders were to be decided in view of these findings. The writ petitions were disposed of accordingly, with the option for assessees to avail remedies under the Act if aggrieved by subsequent orders.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even under the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notice was issued by the JAO and was treated as a notice under Section 148A and Section 148 of the Act. Therefore, the JAO is the most appropriate authority to assess and re-assess. The Court also directed that the procedure laid down under the new regime would have to be followed by the JAO, and no prejudice would be caused to the assessees by this course of action. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' reliance on Rajeev Bansal's case to be misconstrued in the context of their specific facts. The Court also noted that the Supreme Court had recently disposed of SLPs in terms of the Rajeev Bansal judgment in cases like Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and dropping cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months. Appeals against final assessment orders were to be decided in view of these findings.