Rajasthan High Court Judgments — 2025

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings that were originally initiated by them, even after the introduction of the faceless assessment regime and Section 144B of the Income Tax Act, 1961. The Court reasoned that the Supreme Court, in exercising its powers under Article 142 of the Constitution in cases like Ashish Aggarwal's, specifically provided jurisdiction to the JAO under a deemed fiction of law within the new faceless regime. The initial notice issued by the JAO 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 directed that the JAO must follow the procedure laid down under the new regime. 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 non-application of Rajeev Bansal's case to be misconceived. The Court also noted that the facts in Jasjit Singh's case were different as they dealt with notices issued after the faceless regime came into force. The revenue was directed to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously within two months. The writ petitions were disposed of accordingly, with liberty to assessees to avail remedies under the Act if aggrieved by subsequent orders.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings that were originally initiated by them, even after the introduction of the faceless assessment regime and Section 144B of the Income Tax Act, 1961. The Court reasoned that the Supreme Court, in exercising its powers under Article 142 of the Constitution in cases like Ashish Aggarwal's, specifically provided jurisdiction to the JAO under a deemed fiction of law within the new faceless regime. The initial notice issued by the JAO 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 directed that the JAO must follow the procedure laid down under the new regime. 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 non-application of Rajeev Bansal's case to be misconceived. The Court also noted that the facts in Jasjit Singh's case were different as they dealt with notices issued after the faceless regime came into force. The revenue was directed to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously within two months. The writ petitions were disposed of accordingly, with liberty to assessees to avail remedies under the Act if aggrieved by subsequent orders.

The Tribunal held that the Jurisdictional Assessing Officer (JAO) retains jurisdiction to proceed with reassessment proceedings that were originally initiated by them, even after the introduction of the faceless assessment regime and Section 144B of the Income Tax Act, 1961. The Court reasoned that the Supreme Court, in exercising its powers under Article 142 of the Constitution in cases like Ashish Aggarwal's, specifically provided jurisdiction to the JAO under a deemed fiction of law within the new faceless regime. The initial notice issued by the JAO 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 directed that the JAO must follow the procedure laid down under the new regime. 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 non-application of Rajeev Bansal's case to be misconceived. The Court also noted that the facts in Jasjit Singh's case were different as they dealt with notices issued after the faceless regime came into force. The revenue was directed to examine each case individually in light of the Supreme Court's observations in Rajeev Bansal's case, considering limitations and the threshold of Rs. 50,00,000/- for dropping cases. The exercise was to be completed expeditiously within two months. The writ petitions were disposed of accordingly, with liberty to 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 originally issued by them, even in cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed of all petitions.

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 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 issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him. 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 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 that 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' 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-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 disposed of SLPs in terms of Rajeev Bansal's judgment. The Court ordered accordingly, disposing of all petitions. It was clarified that if any assessee is aggrieved by the order passed, they can avail the remedy 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 them, 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, 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. 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-bar provisions. Cases below Rs. 50,00,000/- are to be dropped as per the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. 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 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 them, 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, 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. 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-bar provisions. Cases below Rs. 50,00,000/- are to be dropped as per the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. 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 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 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 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 issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 him, even after 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 initial notice was issued by the JAO and treated as a notice under Section 148A and Section 148 of the old Act. Therefore, the JAO is the best person to assess and re-assess. The Court also 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, to determine if proceedings fall within the limitation period or have become time-barred. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Court rejected the petitioners' contentions and noted that appeals against final assessment orders would 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 in cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed 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 cases where the faceless regime has come into force. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in the 'Ashish Aggarwal' case, provided jurisdiction to the JAO by a deemed fiction of law under the new faceless regime. The Court found that the initial notices were issued by the JAO and were treated as notices under Section 148A and Section 148 of the Act. Therefore, the JAO is best placed 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' regarding limitation and to drop cases where the income escaped is less than Rs. 50,00,000/-, as per the revenue's stand before the Apex Court. The exercise is to be completed within two months. The Court rejected the petitioners' contentions and disposed of all petitions.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

The Tribunal 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 is in effect. The Court reasoned that the Supreme Court, in Ashish Aggarwal's case, exercised its power under Article 142 of the Constitution to provide 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, which was treated as a notice under Section 148A, then the JAO is the 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 period and the revenue's stand before the Apex Court regarding cases below Rs. 50,00,000/-. The Court clarified that appeals against final assessment orders would be decided in view of the findings arrived at. The petitions were disposed of with liberty to the assessees to avail remedies under the Act if aggrieved by any subsequent order.

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. 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. 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 best person 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. The Court disagreed with the Telangana High Court's view 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-barred proceedings. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Tribunal 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 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. 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. 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 best person 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. The Court disagreed with the Telangana High Court's view 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-barred proceedings. Cases below Rs. 50,00,000/- are to be dropped, keeping in view the revenue's stand before the Apex Court. The exercise is to be completed expeditiously, preferably within two months. The Tribunal 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.