Rajasthan High Court Judgments — 2025

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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 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 they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.

The High Court held that the Jurisdictional Assessing Officer (JAO) would continue to have jurisdiction to decide notices that were originally issued by them, even if they were issued prior to the full implementation of the faceless regime. The Court reasoned that the Supreme Court, in exercising its power under Article 142 of the Constitution in Ashish Aggarwal's case, had specifically provided jurisdiction to the JAO under a deemed fiction of law in the new faceless regime. The Court found that the initial notice was issued by the JAO and treated as a notice under Section 148A, and therefore, the JAO was the most appropriate authority to assess and re-assess. The Court also stated that the procedure laid down under the new regime would have to be followed by the JAO and that no prejudice would be caused to the assessees by this course of action. The Court rejected the assessees' submission that the JAO lacked jurisdiction and disagreed with the view taken by the Telangana High Court in Kankanala Ravindra Reddy'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, particularly regarding limitation 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. The Court also noted that recent Supreme Court judgments in Vikram Kapahi, Ashish Acharatlal Varaiya, and Pradeep Himatlal Shah were disposed of in terms of the Rajeev Bansal judgment.