Rajasthan High Court Judgments — 2025

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 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 stated that the procedure laid down under the new regime would have to be followed by the JAO, and 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 Rajeev Bansal's case to be misconceived. The Court clarified that its own 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, 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 was 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) retains jurisdiction to issue notices under Section 148A and proceed with reassessment under Section 148 of the Income Tax Act, 1961, even if issued prior to the full implementation of the faceless regime. The Court reasoned that the JAO, having issued the initial notice, is best placed to assess and re-assess the provisions of law. It was clarified that the JAO must follow the procedures laid down under the new regime, including Section 144-B, 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 Rajeev Bansal's case to be misconceived. The Court noted 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 individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and time-bar 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, and decisions conveyed as per the faceless regime. The Court also referred to 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. Appeals against final assessment orders were to be decided in view of the findings in these writ petitions. 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 him, even if they were deemed to be notices under Section 148A and Section 148 of the Income Tax Act, 1961. The Court reasoned that no prejudice would be caused by this course of action and that the procedure laid down under the new faceless 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 petitioners' contentions to be without force. The Court also clarified that the judgment in Jasjit Singh's case was distinguishable as it dealt with notices issued after the faceless regime had come 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 and time-barred proceedings. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, adhering to 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 noted that appeals against final assessment orders would be decided in view of the findings arrived at. Any aggrieved assessee could avail remedies under the Act.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in the context of the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notices were issued by the JAO and treated as notices under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also directed 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 explicitly 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. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Apex Court. 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 the findings arrived at. All petitions were disposed of.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in the context of the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notices were issued by the JAO and treated as notices under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also directed 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 explicitly 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. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Apex Court. 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 the findings arrived at. All petitions were disposed of.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in the context of the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notices were issued by the JAO and treated as notices under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also directed 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 explicitly 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. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Apex Court. 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 the findings arrived at. All petitions were disposed of.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in the context of the new faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 in Ashish Aggarwal's case, provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notices were issued by the JAO and treated as notices under Section 148A and Section 148 of the old Act. Therefore, the JAO is best placed to assess and re-assess. The Court also directed 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 explicitly 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. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Apex Court. 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 the findings arrived at. All petitions were disposed of.

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 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 JAO must follow the procedure laid down under the new regime. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' reliance on Jasjit Singh's case to be misplaced as the facts were different (notices issued after the faceless regime commenced). The Court also noted that the Bombay High Court's decision in Hexaware Technologies Limited's case did not apply. 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/- 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. The Court also referenced 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. For cases where final assessment orders were passed and appeals were filed, those appeals would be decided in view of the present 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 initial notice was issued by the JAO, and this notice was treated as a notice under Section 148A and Section 148 of the Act. The Court found that no prejudice would be caused by allowing the JAO to proceed, provided the procedures laid down under the new regime are followed. The Court explicitly disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' reliance on Jasjit Singh's case to be misplaced as the facts were different. The Court also noted that the Bombay High Court's judgment in Hexaware Technologies Limited's case did not apply. 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 Supreme Court. The exercise was to be completed expeditiously within two months. The Court also referred to recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah, which disposed of SLPs in terms of the Rajeev Bansal judgment. For cases where final assessment orders were passed and appeals were filed, those appeals would be decided in view of the Court's findings.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide the notices that were originally issued by him, even under the new faceless regime. The Court reasoned that the initial notices were issued by the JAO, and the new procedure under the faceless regime would have to be followed by the JAO. 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' 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. Cases below Rs. 50,00,000/- were to be dropped as per the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months, and decisions conveyed as per the faceless regime. The Court also noted that the Supreme Court had disposed of SLPs in similar matters in terms of the Rajeev Bansal judgment. Appeals against final assessment orders would be decided in view of these findings.

The High Court 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 initial notice was issued by the JAO, and treating it as a notice under Section 148A and Section 148 of the Act means the JAO is best placed to assess and re-assess the provisions of law. The Court found no prejudice in this course of action and rejected the petitioners' submission that the JAO lacked jurisdiction. 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 clarified that its own decision 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 under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, specifically concerning limitation and cases below Rs. 50,00,000/-, which should be dropped. The exercise was to be completed within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings in this judgment. The 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 under the new faceless regime. The Court reasoned that the initial notice was issued by the JAO, and by deeming fiction of law under the new regime, he is the appropriate authority. The Court found no prejudice in this course of action and rejected the assessees' contention that the JAO should not proceed. The Court also noted that appeals against final assessment orders would be decided based on the findings in this judgment. 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-barring provisions. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, as per the revenue's stand before the Supreme Court. This exercise was to be completed expeditiously, preferably within two months, with decisions conveyed to assessees under the faceless regime.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961, even after the introduction of the faceless assessment regime, provided the initial notice was issued by the JAO before the full implementation of the faceless regime. The Court reasoned that the JAO is best placed to assess and re-assess the provisions of law in such cases and that no prejudice would be caused by allowing the JAO to continue proceedings. 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 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 dropping cases below Rs. 50,00,000/- as per the revenue's stand before the Apex Court. The exercise was to be completed expeditiously within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings. The ratio is that the JAO's jurisdiction is preserved for pre-faceless regime notices, and the subsequent faceless regime procedures must be followed. All petitions were disposed of.

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 if those notices 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 the JAO is best placed to assess and re-assess the provisions of law. 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-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. The Court rejected the assessees' contentions that the judgment in Rajeev Bansal's case was not applicable and clarified that any aggrieved assessee could still avail remedies before the appellate authority if orders were passed on merits. The Court also noted that the Supreme Court had disposed of several SLPs in terms of the Rajeev Bansal judgment.

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 to the assessees by this course of action, and the procedure laid down under the new regime would 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 clarified that the facts in Jasjit Singh's case were different as they dealt with notices issued after the faceless regime was in force. The Bombay High Court's decision in Hexaware Technologies Limited's case was also deemed not applicable. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, specifically regarding limitation and time-barring of proceedings. Cases involving less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months, and the decision conveyed to the assessee 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. All petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961, by a deemed fiction of law, as established in Ashish Aggarwal's case. 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 old Act. Therefore, the JAO is the most appropriate authority to assess and re-assess the provisions of law. The court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering whether proceedings fall within the limitation period or have become time-barred. Cases involving less than Rs. 50,00,000/- should be dropped, aligning with the revenue's stand before the Supreme Court. This exercise is to be conducted expeditiously, preferably within two months, and the decision conveyed to the assessee as per the faceless regime. The court rejected the contentions raised by the petitioners and noted that the Supreme Court has also disposed of SLPs in terms of Rajeev Bansal's judgment. For cases where final assessment orders have been passed and appeals are pending, those appeals would be decided in view of the findings herein. The ratio is that the JAO retains jurisdiction for pre-faceless regime notices, and the Supreme Court's directives on limitation and monetary thresholds must be followed.

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 initial notice was issued by the JAO, and this notice was treated as a notice under Section 148A and Section 148 of the Act. Therefore, the JAO, being the authority that initiated the process, is the most appropriate officer to assess and re-assess. The Court emphasized 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 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-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, preferably within two months, and the decision conveyed to the assessee 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 the Rajeev Bansal judgment. Appeals against final assessment orders were to be decided in view of these findings. The writ petitions were disposed of.

The High Court held that the Jurisdictional Assessing Officer 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 initial notice was issued by the Jurisdictional Assessing Officer, who is best placed to assess and re-assess the provisions of law. The procedure laid down under the new regime would have to be followed by the Jurisdictional Assessing Officer, 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 *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 the value of escaped income (cases below Rs. 50,00,000/- to be dropped). The exercise was to be conducted expeditiously within two months. The Court also noted that Supreme Court judgments in *Vikram Kapahi*, *Ashish Acharatlal Varaiya*, and *Pradeep Himatlal Shah* 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 stand decided in view of the present findings.

The High Court 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, provided the initial notices were issued by the JAO. The court reasoned that the JAO is best placed to assess and re-assess the provisions of law in such cases and that no prejudice would be caused by allowing the JAO to continue. 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 dropping cases involving amounts less than Rs. 50,00,000/- as per the revenue's stand before the Supreme Court. The exercise was to be completed expeditiously within two months. The court also noted that appeals against final assessment orders would be decided in view of these findings. 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 Section 148 of the Income Tax Act, 1961, and to proceed with reassessment proceedings, even after the introduction of the faceless assessment regime, provided the initial notices were issued by the JAO. The Court reasoned that the Supreme Court's decision in Ashish Aggarwal's case provided for the jurisdiction of the JAO under the new faceless regime by a deemed fiction of law. The Court found that no prejudice would be caused to the assessees if the JAO continued the proceedings, and 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 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 the limitation period and dropping proceedings for 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 in this judgment. All writ petitions were disposed of accordingly.

The High Court held that the jurisdictional assessing officer retains jurisdiction to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961, even after the introduction of the 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 regarding limitation and the revenue's stand on dropping cases with income below Rs. 50,00,000/-. The exercise was to be completed expeditiously, preferably within two months, and decisions conveyed to assessees under the faceless regime. The Court also noted that appeals against final assessment orders would be decided in line with these findings. The Court rejected the assessees' contentions and ordered accordingly, disposing of all petitions.

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 in the context of the faceless regime. The Court reasoned that the initial notice was issued by the JAO and should reach its logical conclusion with the same officer. While the procedure laid down under the new regime would have to be followed, 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-bar provisions. Cases involving less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Apex Court. This exercise was to be completed expeditiously, preferably within two months, and decisions conveyed to assessees under the faceless regime. The Court noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah also disposed of SLPs 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 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', 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, which 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 to the assessees. 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 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 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', 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, which 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 to the assessees. 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 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 him, even in the context of the new faceless regime. The Court reasoned that the initial notice was issued by the JAO, and this notice was treated as a notice under Section 148A and Section 148 of the Act. The Court found that no prejudice would be caused by allowing the JAO to continue proceedings. The Court explicitly disagreed with 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* by noting that the latter dealt with notices issued after the faceless regime had come into force. The Court directed the revenue to examine each case concerning deemed notices under Section 148 in light of the Supreme Court's observations in *Rajeev Bansal's case*, specifically concerning limitation and time-barring provisions. Cases below Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Apex Court. The exercise was to be completed expeditiously, preferably within two months, and the decision conveyed to 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*. All 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) 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, provided the initial notice was issued by the JAO. The Court reasoned that the faceless regime, by deeming fiction of law, preserves the jurisdiction of the JAO in such matters, as highlighted in the Supreme Court's decision in Ashish Aggarwal's case. The Court found that no prejudice would be caused to the assessees if the JAO continued to proceed with the notices originally issued by them. 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 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 appeals against final assessment orders would be decided based on the findings in this judgment. Any aggrieved petitioner could avail remedies under the Act.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with notices originally issued by him, even under the new faceless regime. The Court reasoned that the JAO, having issued the initial notice, is best placed to assess and re-assess the provisions of law. It was clarified that the procedure laid down under the new regime must 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 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 limitations and time-barring provisions. Cases below 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, with decisions conveyed as per 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 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 initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, it would be logical for the same officer to conclude the proceedings. The Court emphasized that the procedure laid down under the new regime would have to be followed by the JAO, and 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' contentions to be without force. The Court directed the revenue to examine each case relating to deemed notices issued under Section 148 of the Act 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 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 appeals against final assessment orders would be decided in view of the findings arrived at in the judgment. All petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings initiated by him, even under the new faceless regime. The Court reasoned that the Supreme Court's decision in Rajeev Bansal's case, which clarified the validity of notices issued prior to the full implementation of the faceless regime, is applicable. The Court found that no prejudice would be caused to the assessees if the JAO continues to decide the notices originally issued by him, provided the procedure laid down under the new regime is followed. 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 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-bar provisions, and to drop cases below Rs. 50,00,000/- as per the revenue's stand before the Supreme Court. The exercise was to be completed expeditiously within two months. The Court also noted that appeals against final assessment orders would be decided in view of the findings arrived at. The writ petitions were disposed of 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 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 by this course of action. The Court explicitly disagreed with the Telangana High Court's view in Kankanala Ravindra Reddy's case and found the petitioners' contention regarding the non-application of the 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 time-barred proceedings. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Apex Court. 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 reached. Any further aggrieved assessee could avail remedies under the Act.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961, even after the introduction of the faceless regime, provided the initial information or inquiry leading to such notices originated with the JAO. The Court reasoned that the Supreme Court, in its power under Article 142, had provided a deemed fiction of law under the new faceless regime, allowing the JAO to continue proceedings initiated by them. The Court found no prejudice to the assessees by this course of action and disagreed with the view taken by the Telangana High Court in 'Kankanala Ravindra Reddy's case'. The Tribunal 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.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to issue and proceed with notices under Section 148A and Section 148 of the Income Tax Act, 1961, even after the introduction of the faceless regime. The Court reasoned that the initial notice was issued by the JAO, and this authority should logically continue 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 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' contentions relating to 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, particularly concerning limitation and time-barring provisions. Cases involving amounts less than Rs. 50,00,000/- were to be dropped, following the revenue's stand before the Apex Court. The exercise was to be conducted expeditiously, preferably within two months, and decisions conveyed to assessees under the faceless regime. The Court noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah also disposed of SLPs in terms of Rajeev Bansal's judgment. All 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 the notices that were originally issued by him, even after the introduction of the new faceless regime. The Court reasoned that no prejudice would be caused 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 petitioners' contention regarding the non-application of the judgment in Rajeev Bansal's case to be misconceived. The Court clarified that the facts in Jasjit Singh's case were 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, as per 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 that the Supreme Court had disposed of SLPs in terms of the Rajeev Bansal judgment, directing Assessing Officers to dispose of petitions accordingly. The writ petitions were disposed of with liberty to assessees to avail remedies under the Act if still aggrieved.

The High Court held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961. The Court reasoned that the initial notices were issued by the JAO, and these should be treated as notices under Section 148A and Section 148 of the old Act, with the JAO being the appropriate authority to assess and re-assess. The Court clarified that the procedure laid down under the new faceless regime must be followed by the JAO. The Court found no prejudice to the assessees by this course of action and rejected the contention that the Telangana High Court's view in Kankanala Ravindra Reddy's case applied. The Court also distinguished the present cases from its own prior decision in Jasjit Singh's case, where notices were issued after the faceless regime came into force. 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 monetary thresholds (cases below Rs. 50,00,000/- to be dropped). This exercise is to be conducted expeditiously, preferably within two months. The Court also noted that if assessees have filed appeals against final assessment orders, those appeals would be decided in view of the findings in this judgment. The Court rejected the contentions raised by the petitioners, stating that if any assessee is aggrieved by the final order, they can avail the remedy of appeal under the Act. 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 that were originally issued by him, even under the new faceless regime. The Court reasoned that the initial notice was issued by the JAO and, by a deemed fiction of law, this action is considered valid under the new regime, as established in Ashish Aggarwal's case. The Court clarified that while the JAO would proceed, they must follow the procedures laid down under the new regime, including Section 144-B. The Court found no prejudice to the assessees by this course of action and rejected the assessees' contentions. 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 the threshold of Rs. 50,00,000/- for dropping proceedings. The Court noted that appeals against final assessment orders would be decided in view of the findings in these writ petitions. The Court explicitly rejected 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 High Court 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's decision in Ashish Aggarwal's case provided for the jurisdiction of the JAO by deemed fiction of law under the new faceless regime. The Court found that no prejudice would be caused by this course of action and rejected the petitioners' submissions. The Court also distinguished the present cases from Jasjit Singh's case and Hexaware Technologies Limited's case. 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, particularly concerning limitation and time-barred proceedings. Cases involving less than Rs. 50,00,000/- were to be dropped, aligning with the revenue's stand before the Supreme Court. This exercise was to be conducted expeditiously, preferably within two months, and decisions conveyed to assessees in terms of the faceless regime. The Court noted that the Supreme Court had also disposed of SLPs in terms of Rajeev Bansal's case in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in the context of the new faceless regime. 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 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' 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-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. 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. Appeals against final assessment orders were to be decided in view of the findings. All petitions were disposed of.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices originally issued by him, even in cases where the faceless regime has come into force. The Court reasoned that the initial notice was issued by the JAO, and this action should be treated as a notice under Section 148A and Section 148 of the Act. The Court clarified 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' contention relating to 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/- were to be dropped 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 disposed of SLPs in terms of Rajeev Bansal's judgment. Appeals against final assessment orders were to be decided in view of these findings. All petitions were disposed of.

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 issued prior to the full implementation of the faceless regime. The Court reasoned that no prejudice would be caused to the assessees if the JAO, who initially issued the notices, continued with the proceedings, provided they followed the procedure laid down under the new regime. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' 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 issued under Section 148 in light of the Supreme Court's observations in Rajeev Bansal's case, specifically concerning limitation periods and the revenue's stand on dropping 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. Any aggrieved assessee could avail remedies under the Act. The writ petitions were disposed of accordingly.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to proceed with and decide notices that were originally issued by him, even in the context of the new faceless regime. The Court reasoned that no prejudice would be caused to the assessees if the JAO, who issued the initial notices, continued the proceedings. 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 clarified that the facts in Jasjit Singh's case were different as they involved notices issued after the faceless regime was in effect. 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 completed expeditiously, preferably within two months. The Court also noted that appeals against final assessment orders would be decided in view of the 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 that were originally issued by him, 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 procedure laid down under the new regime would still need to be followed by the JAO. 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 "Rajeev Bansal" judgment to be misconceived. The Court clarified that the facts in "Jasjit Singh's" case were different as 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, including the limitation periods and the threshold of Rs. 50,00,000/- for dropping cases, as per the revenue's stand before the Apex Court. The exercise was 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 the "Rajeev Bansal" judgment. The Court further held that appeals against final assessment orders would be decided in view of the findings arrived at in the 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 after the implementation of the faceless regime. The Court reasoned that this approach would not cause prejudice to the assessees 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 distinguished the facts of *Jasjit Singh's case* and *Hexaware Technologies Limited's 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 time-barring 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. The Court noted that appeals against final assessment orders would be decided based on these findings. The operative direction was to dispose of all petitions accordingly, with the option for 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 them, even if they were subsequently treated as notices under Section 148A of the Income Tax Act, 1961. 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 the new faceless regime by a deemed fiction of law. The court found no prejudice in this course of action and rejected the petitioners' submission that the JAO lacked jurisdiction. 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 periods and the dropping of cases with amounts less than 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. Any aggrieved party 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 them, even if they were subsequently treated as notices under Section 148A of the Income Tax Act, 1961. 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 the new faceless regime by a deemed fiction of law. The court found no prejudice in this course of action and rejected the petitioners' submission that the JAO lacked jurisdiction. 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 periods and the dropping of cases with amounts less than 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. Any aggrieved party 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 them, even if they were subsequently treated as notices under Section 148A of the Income Tax Act, 1961. 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 the new faceless regime by a deemed fiction of law. The court found no prejudice in this course of action and rejected the petitioners' submission that the JAO lacked jurisdiction. 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 periods and the dropping of cases with amounts less than 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. Any aggrieved party 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 them, even if they were subsequently treated as notices under Section 148A of the Income Tax Act, 1961. 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 the new faceless regime by a deemed fiction of law. The court found no prejudice in this course of action and rejected the petitioners' submission that the JAO lacked jurisdiction. 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 periods and the dropping of cases with amounts less than 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. Any aggrieved party 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 them, even in the context of the faceless regime, by a deemed fiction of law as per the Supreme Court's exercise of power under Article 142 in Ashish Aggarwal's case. The Court directed the revenue to examine each case individually concerning deemed notices under Section 148, in light of the Supreme Court's observations in Rajeev Bansal's case, specifically regarding limitations and monetary thresholds (cases below Rs. 50,00,000/- to be dropped). The exercise was to be completed expeditiously, preferably within two months. The Court rejected the assessees' contentions and clarified that appeals against final assessment orders would be decided on merits. The judgment noted that recent Supreme Court decisions in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah also disposed of SLPs in terms of Rajeev Bansal's judgment.

The High Court quashed and set aside the notice dated June 17, 2025, issued under Section 148 of the Income-tax Act. The Court found merit in the petitioner's submission that the notice was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), a point extensively dealt with in the cited precedents. While acknowledging the revenue's submission regarding the pending SLP in the Hexaware Technologies Ltd. case and the potential for the Apex Court to interfere with the existing judgments, the Court decided to grant the petitioner's prayer. However, to protect the revenue's interest, the Court granted liberty to the revenue to revive the notice issued under Section 148 if the Apex Court's decision in Hexaware Technologies Ltd., Sharda Devi Chhajer, or Shree Cement Limited is altered. The petition was disposed of with these directions, keeping open all rights and contentions of the parties.

The High Court held that the jurisdictional Assessing Officer (AO) retains the authority to proceed with notices issued under Section 148A and Section 148 of the Income Tax Act, 1961, even if issued prior to the full implementation of the faceless regime. The Court reasoned that the initial notice was issued by the jurisdictional AO, and by a deemed fiction of law under the new regime, this AO has jurisdiction. The Court found no prejudice to the assessees if the jurisdictional AO continued to decide these notices, provided the procedure laid down under the new regime, including Section 144B, is followed. The Court disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case and found the petitioners' reliance on Jasjit Singh's case to be distinguishable due to factual differences. The Court directed the revenue to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, including dropping cases below Rs. 50,00,000/- as per the revenue's stand before the Supreme Court. 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 these findings. The Court rejected the contentions raised by the petitioners and disposed of all petitions.

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 in light of the new faceless regime. The Court reasoned that the JAO, having issued the initial notice, is best placed to assess and re-assess the provisions of law. The procedure laid down under the new regime would, however, have to be followed by the JAO. The Court found no prejudice to the assessees by this course of action and rejected the assessees' submissions. 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 individually in light of the Supreme Court's observations in *Rajeev Bansal's case*, including the monetary limits for dropping cases (less than Rs. 50,00,000/-) as stated by the revenue before the Apex Court. 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 in the judgment. The writ petitions were disposed of accordingly, with the liberty for assessees to avail remedies under the Act if aggrieved by the final order.