Rajasthan High Court Judgments — 2026

The High Court held that the provisional attachment order dated 01.01.2026, issued under Section 281B of the Income Tax Act, 1961, was wholly unjustified and contrary to the purpose sought to be achieved. The Court noted that the petitioner is a regular assessee and has regularly paid taxes. The attachment was based on an apprehension that a demand might be created, even though no demand had been raised yet. The Court relied on the Supreme Court's decision in Radha Krishan Industries Vs. State of Himachal Pradesh & Ors., which emphasized that the power under Section 281B is draconian and must be exercised with strict fulfillment of statutory conditions, requiring tangible material to form an opinion that the assessee is likely to defeat the demand. The Court also highlighted that before invoking Section 281B, authorities must examine if the assessee is a regular tax payer and that such attachments can harm the reputation of honest taxpayers. The Court disapproved of the respondent's approach, set aside the attachment order, and directed the petitioner to deposit 20% of the provisionally assessed demand within one week. It was clarified that if the demand is found unjustified, the deposited amount would be refunded with interest. The Court allowed the writ petition.

The High Court held that the transfer of the case under Section 127 of the Income Tax Act, 1961, for the purpose of coordinated investigation was justified and did not warrant interference, answering this issue in favour of the Revenue. However, the Court found that no factual or actual search was conducted under Section 132 of the Act against the petitioner-company. Despite warrants mentioning the petitioner's name, the conditions under Section 132 were not satisfied. The notices issued under Section 153A lacked reasons and were based on no incriminating material found during the alleged search, which was converted from a survey where premises were found closed. The Court relied on the Supreme Court's decision in Manish Maheshwari vs. ACIT, stating that Section 153A provisions are drastic and require satisfaction of conditions under Section 132. Therefore, the notices under Section 153A were held to be illegal and quashed. The Court further noted that even if the Section 153A notices were valid, the re-assessment proceedings had become time-barred. Consequently, the writ petition was allowed on both counts.

The High Court, upon being informed by the petitioner's counsel that the issue in the present writ petition was identical to that decided by a Co-ordinate Bench in the case of Pramod Jain (supra) on January 27, 2026, disposed of the present writ petition in view of the said judgment. The Court did not independently decide the merits of the case but relied on the precedent set by the Co-ordinate Bench. The specific findings and reasoning of the Pramod Jain judgment are not detailed in this order, nor is the operative direction beyond disposing of the petition. No issue was expressly left undecided.

The High Court allowed the writ petition and set aside the order dated 02/03.04.2018. The Court reasoned that the Department's intention to transfer the petitioner's jurisdiction from Jaipur to Bikaner was solely based on proceedings pending against the Gupta Group. Since these proceedings had been closed and the assessment was over, the Court found no justifiable reason for the Department to transfer the jurisdiction. The ratio decidendi is that a transfer of jurisdiction under Section 127, if based on proceedings that are subsequently closed, lacks a valid foundation. The operative direction was to set aside the impugned order. The Department was granted liberty to take appropriate action in accordance with law. No issue was expressly left undecided.

The High Court held that the ITAT correctly quashed the PCIT's order passed under Section 263 of the Income Tax Act, 1961. The court affirmed that for an order to be subject to revision under Section 263, it must be both erroneous and prejudicial to the interest of the revenue. The Tribunal had found that in the assessee's own case for Assessment Year 2008-09, a coordinate bench had held that provisions for doubtful debts constitute ascertained liabilities, and the PCIT had accepted this position in earlier years. Therefore, the PCIT's contention that doubtful debts are not ascertained liabilities was considered a mere difference of opinion. The court distinguished the present case from the Supreme Court's decision in CIT v. M/s. Paville Projects Pvt. Ltd., where the AO's order was clearly erroneous and prejudicial due to allowing non-allowable expenses. Since the AO's order in the present case was not found to be erroneous, and the PCIT's action was based on a change of opinion, the appeal was dismissed. The court also noted that no substantial question of law arose for its examination.

The Tribunal, in essence, accepted the submission made by the learned counsel for the parties that the issue involved in the present writ petition had already been considered and decided by a Co-ordinate Bench of the High Court. The Court referred to a specific prior judgment, Shree Cement Limited Vs. Deputy Commissioner of Income Tax & Anr. (D.B. Civil Writ Petition No.22244/2018), decided on 04.08.2025. Based on this prior decision, the present writ petition was disposed of. The reasoning is that a Co-ordinate Bench's decision on an identical issue serves as precedent for the current bench. The operative direction was to dispose of the writ petition in line with the aforementioned judgment, and all pending applications were also disposed of accordingly. No specific issue was left undecided; rather, the entire petition was resolved by applying the prior ruling.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly being adjudicated by the Hon'ble Apex Court in Siddharth Totuka's case, it would be appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. 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, including consequential orders or giving effect to any impugned orders, for as long as the interim protection granted by the Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) was stated to govern the outcome of the present petition. The writ petition was disposed of in terms of the order dated January 27, 2026, passed in the case of Pramod Jain, with the observations and directions applying mutatis mutandis.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly being adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders or impugned orders, for as long as the interim protection granted by the Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) was stated to govern the outcome of the present petitions. The writ petitions were disposed of in terms of the order passed in the case of Pramod Jain, with the observations and directions applying mutatis mutandis.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Consequently, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP filed by Siddharth Totuka would govern the outcome of these petitions. The petitions were disposed of in terms of the order passed in the case of Pramod Jain, with the observations and directions applying mutatis mutandis.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential order(s) or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the aforementioned SLP was declared to govern the outcome of the present petitions. No specific finding was given on the merits of the individual cases, as the petitions were disposed of based on the Supreme Court's interim order.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, is directly being adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, is directly being adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it was appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Consequently, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the present petitions is explicitly stated to be governed by the outcome of the aforementioned SLP. No specific finding was given on the merits of the jurisdictional or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that the issue involved in these writ petitions is identical to one previously considered and decided by a co-ordinate bench of the same court in the matter of Pramod Jain Vs. Assistant Commissioner of Income Tax. Furthermore, the Court noted that the Hon'ble Apex Court, in Siddharth Tuka Vs. Assistant Commissioner of Income Tax, had stayed proceedings concerning Section 153C of the Income Tax Act, 1961. Given that the narrow compass of the issue is being directly adjudicated by the Apex Court, the High Court deemed it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues to operate. The outcome of the SLP filed by Siddharth Tuka (tagged with SLP(C) No. 33392 of 2025) will govern the outcome of these petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it was appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Consequently, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the present petitions is explicitly stated to be governed by the outcome of the aforementioned SLP. No specific finding was given on the merits of the jurisdictional or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, is directly being adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that the issue involved in the writ petitions was identical to one previously considered and decided by a co-ordinate bench of the same court. This co-ordinate bench had passed an order based on an interim order from the Hon'ble Apex Court in Siddharth Tuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). In that SLP, the Apex Court had stayed proceedings concerning Section 153C of the Income Tax Act, 1961, including impugned orders passed by the High Court. The High Court found it appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, it directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Apex Court remains in operation. The outcome of the SLP was declared to govern the outcome of the present petitions. The petitions were disposed of accordingly.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the SLP was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the case, as the decision was based on the pendency and interim orders of the Supreme Court.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the issue concerning Section 153C of the Income Tax Act, 1961, is directly being adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it was appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential order(s) or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of this direction.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, including any consequential order(s) or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The outcome of the said SLP shall govern the outcome of the present petitions. The Court explicitly left undecided the merits of the case, deferring to the Supreme Court's final decision.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly being adjudicated by the Hon'ble Apex Court, it was appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. Accordingly, 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 or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. 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 on these terms.

The High Court held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly being adjudicated by the Hon'ble Apex Court, it was appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. 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, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. 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 since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in a related litigation, it was appropriate to dispose of the present writ petition by extending the same protection as granted by the Apex Court. Accordingly, 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, including any consequential orders or giving effect to the impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the present petition was explicitly stated to be governed by the final outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025). No specific issue was left undecided; rather, the decision was deferred pending the Apex Court's ruling.

The High Court held that since the narrow compass of the issue was being directly adjudicated by the Hon'ble Apex Court in SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP would govern the outcome of these petitions. The Court disposed of the writ petitions in terms of the order passed in Pramod Jain, applying the observations and directions mutatis mutandis.

The High Court held that since the narrow compass of the issue was being directly adjudicated by the Hon'ble Apex Court in SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP would govern the outcome of these petitions. The Court disposed of the writ petitions in terms of the order passed in Pramod Jain, applying the observations and directions mutatis mutandis.

The High Court held that since the narrow compass of the issue was being directly adjudicated by the Hon'ble Apex Court in SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP would govern the outcome of these petitions. The Court disposed of the writ petitions in terms of the order passed in Pramod Jain, applying the observations and directions mutatis mutandis.

The High Court held that since the narrow compass of the issue was being directly adjudicated by the Hon'ble Apex Court in SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP would govern the outcome of these petitions. The Court disposed of the writ petitions in terms of the order passed in Pramod Jain, applying the observations and directions mutatis mutandis.

The High Court held that since the narrow compass of the issue was being directly adjudicated by the Hon'ble Apex Court in the Siddharth Totuka litigation concerning Section 153C of the Income Tax Act, 1961, it would be appropriate to dispose of the present writ petitions by extending the same protection as granted by the Hon'ble Apex Court. Accordingly, the Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961, against the petitioners, nor give effect to any consequential or impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. The writ petitions were disposed of in terms of the order passed in the case of Pramod Jain, with the observations and directions applying mutatis mutandis.