Loading High Court cases…
446 orders · Page 2 of 9
The High Court held that the instant appeals had become infructuous. This decision was based solely on the submission made by the learned counsel for the petitioner (appellant). The Court did not delve into the merits of any of the underlying tax disputes or the assessment years involved. The reasoning provided is that the appeals are no longer viable for adjudication. Consequently, the operative direction was to dismiss the appeals as having become infructuous. All pending applications associated with these appeals were also disposed of.
The High Court noted that while the petitioner's counsel argued that proceedings under Section 153B of the Act were barred by limitation, there were no specific pleadings to this effect in the writ petition. The Court observed that the judgment in Tirupati Construction Company (supra) was based on the premise that recourse to Section 148 was made because proceedings under Section 153A were barred by limitation. However, in the present case, the petitioner approached the Court after the final assessment proceedings were concluded and more than a year after the notice was issued. Given this factual matrix and the availability of statutory appeal forums, the Court was not inclined to entertain the writ petition. The petitioner was granted liberty to file an appropriate appeal before the Appellate Authority within 30 days, where all arguments and contentions could be raised. The Appellate Authority was directed to dispose of the appeal within three months.
The High Court disposed of the writ petition based on joint submissions made by learned counsel for the parties. The petitioner was directed to file an application for taking on record his revised return filed pursuant to the notice under Section 148. The respondents were directed to consider this application along with the revised return and pass an appropriate order in accordance with law. The respondents were also directed to furnish all necessary documents to the petitioner, if any, that had not already been supplied. Upon receipt of these documents, the petitioner would be at liberty to file objections within fifteen days. The respondents would then consider and decide the matter strictly in accordance with law by passing a reasoned and speaking order. The Court explicitly stated that it had not examined the merits of the case and that the order should not be construed as an expression of opinion on the merits. All rights and contentions of the parties were kept open.
The High Court, having considered the joint request of the parties, decided to accede to the request for remand. The impugned order dated 08.12.2017 passed by the learned Tribunal, qua the questions of law, was quashed and set aside. The matter was remanded to the Assessing Officer for fresh adjudication of the two issues framed by the Court. The Assessing Officer is directed to decide the matter afresh after affording due opportunity of hearing to all concerned parties. The parties are directed to appear before the Assessing Officer on 07.09.2026 for further proceedings. The specific findings on the merits of the two substantial questions of law were not adjudicated upon as the matter was remanded.
The High Court held that while the case technically fell within the exception recognized under the CBDT Circulars, in view of the insignificant tax effect and the overall policy of reducing unnecessary litigation, it would be appropriate to close the present appeal. The Court explicitly stated that the appeal was dismissed without entering into the merits of the controversy. The substantial question of law proposed by the appellant was kept open and the dismissal was based solely on the aforementioned circulars and the policy of reducing litigation. The dismissal does not preclude the appellant from raising the same issue in an appropriate matter where the factual matrix or tax effect justifies judicial examination. No operative directions were issued regarding the underlying tax dispute.
The High Court, after reviewing the additional affidavit filed by the Department and the annexed screenshot from the CPC 2.0 portal, was satisfied that the refund amount claimed by the original petitioner had already been adjusted by the Department against the pending demand of the petitioner. No counter-affidavit was filed by the original petitioner. Consequently, the application for clarification was allowed. The Court directed that paragraph 6 of the order dated May 17, 2023, be read as modified to include the condition: "if the said amount is already not adjusted against the outstanding demand of previous years." This clarified that the direction to refund was contingent on the amount not having been previously adjusted. The modified paragraph was to be treated as part of the original order.
The High Court held that the Tribunal, as the final fact-finding authority, had appreciated the facts and found no concrete material to conclude that the entries in the books of account were incorrect. The Court noted that the premise of the proceedings was the abnormal sale transactions on a particular date. However, it found that the sales in question and comparative sales were undertaken under entirely different parameters and circumstances. The Court reasoned that abnormal sale transactions might occur due to heavy demand under special circumstances, such as demonetization, leading to increased customer inflow and monetization of funds by purchasing items. The comparative standards adopted by the AO and CIT (Appeals) were not based on the same situation. The Court acknowledged that two views were possible: one that real sales occurred due to special circumstances, and another that artificial sales were created. Since the Tribunal adopted one of the two possible views, the High Court found no perversity and no substantial question of law arose.
The High Court observed that the seized cash had been with the respondents since April 10, 2024, and the petitioners' application for its release was already pending before the Competent Authority. No useful purpose would be served by keeping the writ petition pending. Therefore, the Court directed the Competent Authority to treat the writ petition, read with the application at Annexure-6, as the petitioners' representation for the release of the seized cash. The Competent Authority was instructed to afford the petitioners an opportunity of personal hearing and pass a reasoned order within four weeks from the date of uploading the order. The remaining prayers were left open to be agitated in appropriate proceedings if the occasion arose. The petition was disposed of in these terms.
The High Court, acknowledging that the issue was identical to a previous matter (D.B. CWP No.1486/2026) where similar protection was granted based on an Apex Court order, decided to dispose of the present writ petition in the same terms. The Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioner, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 continues. The outcome of the said SLP was declared to govern the outcome of the present petition. No specific issue was left undecided, as the matter was disposed of based on the Apex Court's interim order.
The High Court disposed of the writ petition in terms of the order dated 21.08.2025 passed in D.B. Civil Writ Petition No.14638/2022. This order directed that cases falling below the value of Rs.50,00,000/- would have to be dropped, keeping in view the stand taken by the Revenue before the Apex Court as observed in paragraph No.53 of the Rajeev Bansal judgment. The Court further stipulated that the concerned competent officer of the Department should conduct this exercise expeditiously, preferably within two months, and convey the decision to the assessee in terms of the faceless regime, adhering to Section 144-B of the Act. The contentions raised before the Bench were rejected in light of this consensus and the cited Supreme Court judgments. No specific finding was recorded on the merits of the petitioner's case, as the disposal was based on the agreed terms and prior judicial pronouncements.
The Tribunal held that since the Hon'ble Apex Court was directly adjudicating the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, it would be appropriate to dispose of the present writ petition by extending the same protection as granted by the Hon'ble Apex Court. The Tribunal directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioner, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petition. The writ petition was disposed of accordingly.
The High Court held that the petition was rendered infructuous. This decision was based on the submission made by the learned counsel for the petitioner. Consequently, the Court ordered the disposal of the writ petition as infructuous, as prayed for by the petitioner's counsel. The reasoning is solely based on the petitioner's assertion that the matter no longer required adjudication on merits. The operative direction was to dispose of the petition. All pending applications, if any, were also disposed of. No other issues were decided, and no specific ratio decidendi for future citation on substantive tax matters can be extracted.
The High Court disposed of all the applications in terms of a previous order dated 30.06.2026 passed by a co-ordinate bench. That order had dismissed the Department's application for recalling a previous order, stating that the pendency of Special Leave Petitions (SLPs) before the Supreme Court against the High Court's order was not a ground for recall. The co-ordinate bench had observed that if a similar order was passed by the Supreme Court in the SLPs, the writ petitions would automatically stand revived or revival could be sought. In the present case, the learned counsel for the applicants stated that all these applications should be disposed of accordingly. Therefore, the applications for recalling the order dated 01.09.2025 and restoring the writ petitions were dismissed in terms of the aforementioned order.
The High Court held that the writ petition was not maintainable. The primary reason was the existence of an efficacious alternative statutory remedy under Section 246 of the Income Tax Act, 1961, which the petitioner had failed to avail. The Court noted that the writ petition was filed beyond the limitation period prescribed under Section 249 of the Act. However, instead of outright dismissing the petitioner's attempt to seek redressal, the Court dismissed the writ petition with liberty to the petitioner to raise all his legal and factual grounds before the appellate authority. Furthermore, in exercise of its jurisdiction under Article 226 of the Constitution of India, the Court directed that the time taken by the petitioner in pursuing the writ petition before the High Court would be excluded by the Appellate Authority while calculating the limitation period for entertaining the appeal, provided the appeal is filed within 30 days from the date of this order.
The High Court, in these miscellaneous applications, disposed of all the applications in terms of the order dated 30.06.2026 passed by a Co-ordinate Bench. The Co-ordinate Bench had dismissed the Department's application for recalling its earlier order. The reasoning was that the Department's application was misconceived as an SLP against the High Court's order was pending before the Hon'ble Supreme Court. The Court held that it would not recall its earlier order based on another case's judgment when its own order was under challenge. The Department was advised to move an appropriate application for disposal of the SLPs, and if a similar order was passed by the Supreme Court, the writ petitions would automatically stand revived or revival could be sought. The operative direction was to dismiss the present miscellaneous applications in terms of the aforementioned order, with a concession allowing the applicants to take back their certified copies.
The High Court agreed with the Assessing Officer's reasoning that the reopening was not a mere change of opinion but based on facts not previously examined. The Court noted that while reassessment cannot be based on a change of opinion on the same material, it is permissible when a ground for reopening was never considered or examined in the original assessment. The notice arose from an aspect that genuinely escaped the Assessing Officer's attention: whether an amount allowed as expenditure qualified for that treatment. However, the Court acknowledged that under Section 2(9) of the Rajasthan Money Lending Act, 1963, money advanced through negotiable instruments falls outside the licensing requirement of Section 5. The petitioner's objection regarding negotiable instruments lacked specific particulars (cheque numbers, etc.) before the Assessing Officer. The Court, not inclined to speculate or make findings on unsupported submissions, affirmed the rejection of objections but granted liberty to the petitioner to place particulars of negotiable instruments on record. The Assessing Officer is to examine these particulars and proceed accordingly if transactions qualify for exemption under Section 29 of the Act. The writ petition was disposed of with these observations.
The Court held that the reassessment proceedings were not sustainable. The assessment for AY 2014-15 was completed under Section 143(3) on 30.12.2016. The reassessment notice under Section 148 was issued on 26.03.2021, which is beyond four years from the end of the relevant assessment year. According to the first proviso to Section 147, reopening beyond four years is permissible only if income escaped assessment due to the assessee's failure to fully and truly disclose all material facts. The Court found that during the original scrutiny, the Assessing Officer had specifically inquired about the property sale, and the petitioner had provided a detailed explanation regarding the sale consideration and the additional amount attributed to stamp duty due to a company name change. The Court noted that the reasons recorded for reopening did not identify any specific material fact that was withheld by the petitioner. Therefore, the reassessment was based on the same material already disclosed during the original assessment. A different view taken by the AO on the disclosed material, in the absence of any failure to disclose, cannot justify reopening beyond the statutory period. The jurisdictional requirement under the first proviso to Section 147 was not satisfied.
The High Court disposed of the applicant's miscellaneous application in terms of the order passed by a coordinate bench on 01.07.2026. The coordinate bench had dismissed a similar application filed by the Department seeking recall of an order. The reasoning was that the SLP against the High Court's order was still pending before the Supreme Court. The coordinate bench held that it would not recall its earlier order solely based on another case's order, especially when the appeal against its own order was sub-judice. It was observed that if the Supreme Court passed a similar order in the pending SLP, the writ petitions would automatically stand revived or revival could be sought. The High Court, by adopting this order, implicitly held that the present application for recalling the order dated 01.09.2025 was also not maintainable in the current circumstances, pending the outcome of the SLP before the Supreme Court. The operative direction was to dispose of the application in terms of the earlier order.
The High Court disposed of all the writ miscellaneous applications in terms of the order dated 30.06.2026 passed by a co-ordinate bench. The co-ordinate bench's order had dismissed the Department's application for recalling an earlier order, finding it misconceived because an SLP against the High Court's order was pending before the Supreme Court. The co-ordinate bench observed that the Department could move an appropriate application for disposal of the SLPs, and if a similar order was passed by the Supreme Court, the writ petitions would automatically stand revived or revival could be sought from the court. The High Court allowed the prayer for handing over back the certified copies of the original documents filed by the applicants. Therefore, the present applications were dismissed with these observations, and no decision on the merits of the original writ petitions was made.
The High Court dismissed the appeal for non-prosecution. The reasoning was based on the submission by the appellant's counsel that he had no instructions from his client, rendering further prosecution impossible. While the revenue argued that the questions of law were already decided in their favour by the Kerala High Court, the Court did not delve into the merits of these arguments. The operative direction was to dismiss the appeal. The questions of law framed by the Court were expressly left open to be decided in appropriate future proceedings, should the occasion arise. No finding was given on the merits of the case.
The High Court allowed the petitioner's application to withdraw the writ petition. The Court granted permission to the petitioner to withdraw the present writ petition. Consequently, the writ petition was dismissed as withdrawn. No decision on the merits of the case was made. The operative direction was to dismiss the petition as withdrawn, along with any pending applications.
The High Court dismissed the writ petition. The Court noted that despite the explicit direction on May 5, 2026, to amend the writ petition by May 25, 2026, the petitioner failed to do so. Consequently, the petition was dismissed for non-compliance with the Court's order. All pending applications were also dismissed. The judgment does not specify the original grounds of the writ petition or the nature of the dispute, as the dismissal was procedural.
The High Court held that the petitioner had failed to file the amended writ petition within the time granted by the court. The court noted that despite the explicit direction passed on May 5, 2026, and the subsequent listing of the case on May 27, 2026, the petitioner had not complied. Consequently, the court dismissed the writ petition. All pending applications associated with the writ petition were also dismissed. The judgment does not delve into the substantive merits of the original writ petition or the assessment proceedings.
The Court held that the petitioner had not filed the amended writ petition within the stipulated time, despite the clear directions issued on May 5, 2026, which were based on a Supreme Court judgment. Consequently, the Court dismissed the writ petition. The reasoning was based on the non-compliance with the procedural direction. The ratio decidendi is that failure to comply with court orders, especially those referencing higher judicial pronouncements, leads to dismissal of the petition. The operative direction was the dismissal of the writ petition and all pending applications. No issues were left undecided; the petition was disposed of on procedural grounds.
The High Court dismissed the writ petition. The reasoning was that the petitioner failed to comply with the court's explicit direction dated May 5, 2026, which mandated the amendment of the writ petition by May 25, 2026. This direction was given in light of a Supreme Court judgment. Since the petitioner did not file the amended writ petition within the stipulated time, the court found no alternative but to dismiss the petition. The principle here is that non-compliance with court orders, especially procedural directions, can lead to the dismissal of a case. All pending applications were also dismissed as a consequence of the main petition's dismissal. No specific issue regarding the merits of the original writ petition was decided.
The Tribunal held that the petitioner had failed to file the amended writ petition within the stipulated time, despite the clear directions from the Court on May 5, 2026. The Court noted that the Supreme Court's judgment in SLP (C). Diary No(s). 2196/2026, Income Tax Officer, Ward 2(1), Chandigarh & Ors. Vs. Tej Partap Singh, was the basis for the amendment direction. As the petitioner did not comply with the order to amend the petition by May 25, 2026, the Court dismissed the writ petition. The reasoning is based on the non-compliance with a direct court order. The operative direction was to dismiss the writ petition and all pending applications.
The High Court dismissed the writ petition. The court noted that despite a clear direction issued on 05.05.2026, granting four weeks' time to amend the writ petition by 25.05.2026, the petitioner failed to comply with this order. Consequently, the court found no alternative but to dismiss the petition. The court also dismissed all pending applications. No specific issue regarding the merits of the original writ petition was decided, as the dismissal was procedural.
The Tribunal decided that the writ petition should be dismissed. The reasoning was based on the petitioner's failure to comply with the Court's explicit direction dated May 5, 2026, which mandated the amendment of the writ petition within four weeks, by May 25, 2026. This direction was issued in light of a Supreme Court judgment. Since the petitioner did not file the amended petition within the stipulated time, the Court found no alternative but to dismiss the writ petition. The operative direction was the dismissal of the writ petition and all pending applications.
The High Court dismissed the writ petition. The court noted that despite a clear direction issued on May 5, 2026, to amend the writ petition by May 25, 2026, the petitioner failed to comply with this order. Consequently, the court found no alternative but to dismiss the petition. All pending applications associated with the writ petition were also dismissed. The judgment does not delve into the merits of the original writ petition or the issues that might have been raised therein, as the dismissal was purely on procedural grounds of non-compliance with the court's directive.
The High Court dismissed the writ petition. The Court observed that despite a clear direction issued on 05.05.2026, requiring the petitioner to amend their writ petition by 25.05.2026 in accordance with the Supreme Court's judgment in SLP (C). Diary No(s). 2196/2026, Income Tax Officer, Ward 2(1), Chandigarh & Ors. Vs. Tej Partap Singh, the petitioner failed to comply with this order. Consequently, the Court found no alternative but to dismiss the petition for non-compliance. The operative direction was the dismissal of the writ petition and all pending applications. No specific issue regarding the merits of the original petition was decided.
The High Court held that the petitioner had failed to comply with the Court's explicit direction dated May 5, 2026, to amend their writ petition by May 25, 2026. The Court noted that despite the clear order and the stipulated timeframe, the petitioner did not file the amended petition. Consequently, the Court dismissed the writ petition. The reasoning is based solely on the non-compliance with the procedural direction. No decision was made on the merits of the original petition or the issues it raised. All pending applications were also dismissed as a consequence of the main petition being dismissed.
The Tribunal noted that despite the clear direction from the Court on May 5, 2026, to amend the writ petition by May 25, 2026, the petitioner failed to do so. Consequently, the Court held that the writ petition stands dismissed due to non-compliance with the Court's order. The reasoning is straightforward: the petitioner did not fulfill the procedural requirement set by the Court within the given timeframe. No decision was made on the merits of the original writ petition. All pending applications associated with the writ petition were also dismissed.
The High Court dismissed the writ petition. The Court noted that despite the clear direction issued on 05.05.2026, requiring the petitioner to amend their writ petition by 25.05.2026, the petitioner failed to comply with this order within the stipulated time. Consequently, the Court found no alternative but to dismiss the petition. The reasoning is based on the principle that litigants must adhere to court orders and procedural timelines. Failure to do so, without any valid explanation or amendment filed, leads to the dismissal of the case. All pending applications associated with the writ petition were also dismissed as a consequence of the main petition's dismissal. No specific findings were made on the merits of the underlying tax dispute.
The Court held that the petitioner had failed to comply with the specific direction issued on May 5, 2026, to amend the writ petition by May 25, 2026. The Court noted that the petitioner was given four weeks' time to make the amendments, referencing a Supreme Court judgment. Since the petitioner did not file the amended petition within the stipulated period, the Court found no reason to proceed with the writ petition. Consequently, the Court dismissed the writ petition. Any pending applications associated with the petition were also dismissed.
The High Court held that the writ petition stood dismissed. This decision was based on the petitioner's failure to file the amended writ petition within the four-week period granted by the court on 05.05.2026, which was to be completed by 25.05.2026. The court had explicitly stated that the amendment was to be made if the petitioner chose to do so, but the subsequent order indicates non-compliance. The reasoning is procedural: the petitioner did not adhere to the court's directive. The ratio decidendi is that failure to comply with a court's order for amendment within the given time leads to the dismissal of the writ petition. The operative direction was the dismissal of the writ petition and all pending applications.
The Tribunal noted that despite the specific direction from the High Court on 05.05.2026 to amend the writ petition by 25.05.2026, the petitioner had not filed the amended writ petition within the stipulated time. Consequently, the High Court dismissed the writ petition. No specific findings were made on the merits of the original writ petition or the issues that might have been raised therein. The operative direction was the dismissal of the writ petition. No issues were expressly left undecided, as the dismissal was based on procedural non-compliance.
The High Court noted that despite the clear direction issued on May 5, 2026, to amend the writ petition by May 25, 2026, the petitioner failed to file the amended petition within the stipulated time. Consequently, the Court dismissed the writ petition on the ground of non-compliance. All pending applications associated with the writ petition were also dismissed. The judgment does not delve into the merits of the original writ petition or any substantive tax law issues, as the dismissal was purely procedural. No specific ratio decidendi for a substantive legal principle can be extracted from this order.
The Court held that the petitioner had failed to comply with the specific direction issued on May 5, 2026, to amend the writ petition by May 25, 2026. As a consequence of this non-compliance, the Court dismissed the present writ petition. The reasoning is based solely on the procedural default of the petitioner. No decision was made on the merits of the original writ petition. All pending applications were also dismissed as a consequence of the main petition being dismissed.
The High Court noted that despite the clear direction passed on 05.05.2026, granting four weeks' time to amend the writ petition, the petitioner failed to file the amended petition within the stipulated period. Consequently, the Court held that the writ petition was not pursued diligently by the petitioner. Based on this non-compliance, the High Court dismissed the writ petition. No decision was made on the merits of the original writ petition as it was dismissed on a procedural ground. The operative direction was the dismissal of the writ petition and all pending applications.
The High Court held that the writ petition should be dismissed because the petitioner failed to file the amended writ petition within the time granted by the court. The court had specifically directed the amendment by May 25, 2026, following the Supreme Court's order in the Tej Partap Singh case. As the petitioner did not comply with this direction, the court dismissed the writ petition. The reasoning is based on the procedural default of the petitioner in adhering to the court's order. No decision was made on the merits of the original writ petition. All pending applications were also dismissed.
The Court held that despite the clear direction issued on May 5, 2026, to amend the writ petition by May 25, 2026, the petitioner failed to comply with this order within the stipulated time. Consequently, the writ petition was dismissed. The Court did not delve into the merits of the original petition or the issues that might have arisen from the Supreme Court's judgment. The operative direction was the dismissal of the writ petition. No issues were expressly left undecided; the decision was based on procedural non-compliance.
The Court held that the petitioner had not filed the amended writ petition within the stipulated time as directed by the Court's order dated May 5, 2026. Consequently, the writ petition was dismissed. The Court's reasoning was based on the direct non-compliance with its procedural order. No specific arguments from either side are recorded in the judgment regarding this procedural lapse. The operative direction was the dismissal of the writ petition. No issues were decided on merits.
The High Court dismissed the writ petition. The reasoning was solely based on the petitioner's failure to comply with the court's explicit direction to amend the writ petition within the stipulated time granted on May 5, 2026. The court noted that the deadline for amendment was May 25, 2026, and the petitioner did not file the amended petition. Consequently, the writ petition was dismissed as per the order dated May 27, 2026. No decision was made on the substantive merits of the case, as the dismissal was procedural. All pending applications were also dismissed.
The High Court dismissed the writ petition. The Court noted that despite the explicit direction given on 05.05.2026, which allowed four weeks' time to amend the writ petition on or before 25.05.2026, the petitioner failed to file the amended petition within the stipulated period. Consequently, the Court found no alternative but to dismiss the present writ petition. All pending applications were also dismissed as a consequence of the main petition being dismissed. The judgment does not record any specific findings on the merits of the case, as the dismissal was based on procedural grounds.
The Tribunal dismissed the writ petition. The reason for dismissal was the petitioner's failure to comply with the Court's explicit direction to amend the writ petition by May 25, 2026. The Court had granted a specific timeframe of four weeks, referencing a Supreme Court order, to allow for such amendments. As the petitioner did not adhere to this deadline, the Court found no alternative but to dismiss the petition. No decision was made on the merits of the original petition. All pending applications were also dismissed.
The High Court held that the petitioner failed to comply with the specific direction issued on May 5, 2026, which required amendment of the writ petition by May 25, 2026, following the Supreme Court's guidance in the Tej Partap Singh case. As the petitioner did not file the amended writ petition within the stipulated period, the Court found no alternative but to dismiss the writ petition. The reasoning is based on the procedural non-compliance by the petitioner. The Court also dismissed all pending applications. No specific issue regarding the merits of the assessment or the tax dispute was decided.
The High Court held that the petitioner had failed to file the amended writ petition within the stipulated time granted by the Court's order dated 05.05.2026. Consequently, the Court dismissed the writ petition. The reasoning was based on the direct non-compliance with the Court's explicit direction. The operative direction was the dismissal of the writ petition and all pending applications. No issue was expressly left undecided.
The Tribunal held that the petitioner's prayer for withdrawal of the writ petition with liberty to file a fresh one should be granted. The reasoning was based on the judgment passed by the Hon'ble Supreme Court in the case of Income Tax Officer Vs. Tej Pratap Singh. The principle established is that a party can withdraw a petition with liberty to refile, especially in light of new judicial pronouncements. The operative direction was to dismiss the petition as withdrawn with the liberty granted. No issues were left undecided.
The Tribunal held that the notice dated 19.03.2026 issued under Section 148 of the Income Tax Act, 1961, and the sanction note dated 18.03.2026, along with all consequential proceedings, were without jurisdiction and liable to be quashed. The reasoning was that the issue concerning interest income from deposits and its disclosure had already been examined and conclusively adjudicated by the CIT(A) in its order dated 04.12.2025. No new material had surfaced thereafter, and the reassessment notice was merely a re-examination of a concluded matter, constituting a 'change of opinion'. The Tribunal found that the appellate order had attained finality, and therefore, the subsequent notice for reopening the assessment on the basis of the same facts and material was beyond the jurisdiction of the Assessing Officer. The action of the Assessing Officer in revisiting the concluded matter was deemed an overreach of authority and an improper exercise of power. The writ petition was allowed, and the impugned notice and sanction note were set aside.