Rajasthan High Court Judgments — 2026

The High Court held that as long as the law declared in Sharda Devi Chhajer and Hexaware Technologies Ltd. continues to hold that jurisdiction vests with the Faceless Assessing Officer, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 20.03.2024 under Section 148 and the assessment order dated 16.03.2025, along with all consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that liberty is reserved for the respondent-Revenue to proceed afresh through the Faceless Assessing Officer, strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds were not being pressed. The writ petition was disposed of.

The Tribunal held that as long as the law declared in Sharda Devi Chhajer (supra) and Hexaware Technologies Ltd. (supra) – which established that jurisdiction vests with the Faceless Assessing Officer – continues to be in effect, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 20.03.2024 under Section 148 and the assessment order dated 09.03.2025, along with consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that the respondent-Revenue is at liberty to proceed afresh through the Faceless Assessing Officer, strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds were not being pressed and would be taken up at an appropriate stage if required. The writ petition was disposed of.

The High Court held that as long as the law declared in Sharda Devi Chhajer (supra) and Hexaware Technologies Ltd. (supra) continues to hold that jurisdiction vests with the Faceless Assessing Officer, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 01.03.2025 issued under Section 148 of the Income Tax Act, 1961, and all consequential proceedings were quashed and set aside for being without jurisdiction. The Court clarified that liberty is reserved in favour of the respondent-Revenue to proceed afresh through the Faceless Assessing Officer (FAO), strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds raised were not being pressed and would be taken up at an appropriate stage if required.

The High Court held that as long as the law declared in Sharda Devi Chhajer and Hexaware Technologies Ltd. (holding that jurisdiction vests with the Faceless Assessing Officer) remains in force, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 31.03.2022 issued under Section 148 of the Income Tax Act, 1961, and the assessment order dated 31.03.2023, along with all consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that liberty is reserved for the respondent-Revenue to proceed afresh through the Faceless Assessing Officer (FAO), strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds were not being pressed and would be taken up at an appropriate stage if required. The writ petition was disposed of.

The High Court noted that the final order was passed after the notice was issued by the Jurisdictional Assessing Officer, despite the introduction of the faceless regime. Citing the judgments in Jasjit Singh vs. Union of India & Ors. and Sharda Devi Chhajer & Anr. vs. The Income Tax Officer & Anr., the Court acknowledged that proceedings could not have been initiated by the JAO, nor could the faceless regime have passed orders later if the initial step was flawed. However, since an appeal had already been preferred against the final assessment order, the Court deemed it inappropriate to pass an order that would render the pending appeal redundant. Therefore, the Court directed the petitioner to file an application before the concerned Commissioner of Income Tax (Appeals). The CIT(A) was directed to consider this application and pass appropriate orders within 15 days, taking into account the Court's prior judgments quashing proceedings based on notices issued by a JAO. The writ petition was disposed of with this direction.

The High Court held that so long as the law declared in Sharda Devi Chhajer and Hexaware Technologies Ltd. continues to hold that jurisdiction vests with the Faceless Assessing Officer, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 20.02.2024 under Section 148 and the assessment order dated 10.03.2025, along with all consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that liberty is reserved for the Revenue to proceed afresh through the Faceless Assessing Officer, strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds were not being pressed and would be taken up at an appropriate stage if required. The writ petition was disposed of.

The Court noted that the final order was passed after the notice was issued by the Jurisdictional Assessing Officer, despite the introduction of the faceless regime. Citing the judgments in Jasjit Singh vs. Union of India & Ors. and Sharda Devi Chhajer & Anr. vs. The Income Tax Officer & Anr., the Court acknowledged that proceedings could not have been initiated by the JAO, nor could the faceless regime have passed orders later if the initial notice was invalid. However, as an appeal against the final order was already preferred, the Court deemed it inappropriate to pass orders that would render the appeal redundant. Therefore, the Court directed the petitioner to file an application before the concerned Commissioner of Income Tax (Appeals). The CIT(A) was directed to consider this application and pass appropriate orders within 15 days, taking into account the Court's prior judgments quashing proceedings based on notices issued by the JAO. The writ petition was disposed of with this direction.

The High Court noted that the issue raised by the petitioner regarding the invalidity of notices issued by the Jurisdictional Assessing Officer (JAO) instead of a Faceless Assessing Officer had been adjudicated in prior judgments, specifically D.B. Civil Writ Petition No.11787/2024: Sharda Devi Chhajer & Anr. Vs The Income Tax Officer & Anr. and CWP No.21509/2023: Jasjit Singh vs. Union of India & Ors. These judgments held that notices issued under Section 148 by the JAO were contrary to the provisions of the Act and the faceless regime, and therefore liable to be quashed. However, in the present case, the final assessment order was passed after the notice was issued by the JAO, and appeals were already preferred against this final order. The Court found it inappropriate to pass orders that would render the pending appeals redundant. Consequently, the Court directed the petitioner to file an application before the concerned Commissioner of Income Tax (Appeals), who was directed to consider it and pass appropriate orders within 15 days, taking into account the prior judgments of the High Court quashing proceedings based on notices issued by the JAO. The writ petition was disposed of with this direction.

The High Court noted that the issue of notices under Section 148 by the Jurisdictional Assessing Officer, instead of adhering to the algorithm-based random assignment system envisaged by Section 151A and the faceless regime, has been held to be bad in law by coordinate benches in D.B. Civil Writ Petition No.11787/2024 (Sharda Devi Chhajer & Anr. Vs The Income Tax Officer & Anr.) and CWP No.21509/2023 (Jasjit Singh vs. Union of India & Ors.). These judgments quashed such notices and subsequent proceedings. However, in the present case, the final assessment order was passed after the notice was issued by the JAO, and appeals against this order are pending. The Court deemed it inappropriate to pass an order that would render the pending appeals redundant. Therefore, the Court directed the petitioner to file an application before the Commissioner of Income Tax (Appeals), who was directed to consider it and pass appropriate orders within 15 days, taking into account the prior judgments quashing proceedings based on notices issued by the JAO. The writ petition was disposed of on this basis.

The Court held that as long as the law declared in Sharda Devi Chhajer (supra) and Hexaware Technologies Ltd. (supra) continues to hold that jurisdiction vests with the Faceless Assessing Officer, notices issued by the Jurisdictional Assessing Officer are not legally sustainable. Consequently, the impugned notice dated 01.03.2025 issued under Section 148 of the Income Tax Act, 1961, along with all consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that liberty was reserved in favour of the respondent-Revenue to proceed afresh through the Faceless Assessing Officer (FAO), strictly in accordance with law and the prevailing statutory framework, subject to limitation and other legal requirements. The petitioner stated that other grounds were not being pressed and would be taken up at an appropriate stage. The writ petition was disposed of.

The High Court held that as long as the law declared in Sharda Devi Chhajer (supra) and Hexaware Technologies Ltd. (supra) continues to hold that jurisdiction vests with the Faceless Assessing Officer (FAO), notices issued by the Jurisdictional Assessing Officer (JAO) would not be legally sustainable. Consequently, the impugned notice dated 20.06.2025 issued under Section 148 of the Income Tax Act, 1961, along with all consequential proceedings, were quashed and set aside for being without jurisdiction. The Court clarified that liberty was reserved for the respondent-Revenue to proceed afresh through the Faceless Assessing Officer (FAO), strictly in accordance with law and the prevailing statutory framework, subject to limitations and other legal requirements. The petitioner stated that other grounds were not being pressed and would be taken up at an appropriate stage if required.

The High Court noted that the final assessment order was passed after the notice was issued by the JAO, despite the introduction of the faceless regime. Citing the judgments in Jasjit Singh and Sharda Devi Chhajer, the Court reiterated that proceedings could not have been initiated by the JAO, nor could the faceless regime have passed orders subsequently if the initial notice was flawed. However, as an appeal against the final order was already preferred, the Court deemed it inappropriate to pass an order that would render the appeal redundant. Consequently, the Court directed the petitioner to file an application before the Commissioner of Income Tax (Appeals). The CIT(A) was directed to consider this application and pass appropriate orders within 15 days, taking into account the High Court's previous judgments quashing proceedings based on notices issued by the JAO. The writ petition was disposed of with this direction.

The Rajasthan High Court, Jaipur Bench, acknowledged that the core issue concerning Section 153C of the Income Tax Act, 1961, was under direct adjudication by the Hon'ble Supreme Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). The Court noted the interim order passed by the Apex Court on December 8, 2025, which stayed proceedings under Section 153C. Consequently, the High Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C against the petitioners, including consequential orders, for as long as the interim protection granted by the Supreme Court remains in effect. The outcome of the SLP was declared to govern the outcome of these writ petitions. No specific finding was made on the merits of the jurisdictional or limitation arguments, as the matter was stayed pending the Supreme Court's decision.

The Rajasthan High Court, while acknowledging that the core issue concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication before the Hon'ble Apex Court in SLP No. 31711/2025 (and tagged SLP(C) No. 33392/2025), found it appropriate to extend the same protection granted by the Apex Court to the present writ petitions. 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 declared to govern the outcome of these writ petitions. 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 Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 High Court held that since the narrow compass of the issue concerning Section 153C was being adjudicated by the Apex Court, it was appropriate to grant similar protection. The outcome of the present petitions is explicitly stated to be governed by the final outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025). 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 Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 High Court held that since the narrow compass of the issue concerning Section 153C was being adjudicated by the Apex Court, it was appropriate to grant similar protection. The outcome of the present petitions is explicitly stated to be governed by the final outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025). 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 Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Apex Court continues. The Court held that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petitions. No specific finding was made on the merits of the jurisdiction or limitation arguments, as the matter was stayed pending the Apex Court's decision.

The Rajasthan High Court, while acknowledging that the core issue concerning Section 153C of the Income Tax Act, 1961, was under adjudication before the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025), decided to extend the same protection granted by the Apex Court to the petitioners. 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 declared to govern the outcome of these writ petitions. No specific finding was made on the merits of the Section 153C proceedings themselves, as the matter was deferred pending the Apex Court's decision.

The Rajasthan High Court, in its order dated 27/01/2026, decided to dispose of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court. The Court noted that the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, was being adjudicated by the Supreme Court in SLP No. 31711/2025. Consequently, the High Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C against the petitioners, including any consequential orders or giving effect to impugned orders, for as long as the interim protection granted by the Supreme Court continues. The outcome of the SLP is stated to govern the outcome of these writ petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments.

The Court held that since the narrow compass of the issue, specifically concerning Section 153C of the Income Tax Act, 1961, is 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. 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 continues. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of these petitions. The writ petitions were disposed of accordingly.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble 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 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 in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) continues to operate. The Court held that the outcome of the said SLP shall govern the outcome of the present writ petitions. No specific finding was given on the merits of the Section 153C proceedings themselves, as the matter was stayed pending the Supreme Court's decision.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 Court explicitly stated that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present writ petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments in these petitions, as they were disposed of based on the Apex Court's order.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 Court explicitly stated that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present writ petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments in these petitions, as they were disposed of based on the Apex Court's order.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 Court explicitly stated that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present writ petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments in these petitions, as they were disposed of based on the Apex Court's order.

The Rajasthan High Court, Jaipur Bench, disposed of the writ petitions by extending the same protection as granted by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). 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 Court explicitly stated that the outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present writ petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments in these petitions, as they were disposed of based on the Apex Court's order.

The Rajasthan High Court held that since the narrow compass of the issue, specifically concerning Section 153C of the Income Tax Act, 1961, was being directly adjudicated by the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025), it was appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court continues. The outcome of the SLP was declared to govern the outcome of these writ petitions. No specific finding was made on the merits of the Section 153C proceedings themselves, as the matter was deferred pending the Supreme Court's decision.

The Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, 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 SLP No. 31711/2025, it would be appropriate to dispose of the present writ petitions 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 petitioners, including consequential orders or giving effect to any 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 these petitions. 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 Rajasthan High Court, Jaipur Bench, acknowledged that the core issue concerning Section 153C of the Income Tax Act, 1961, was under adjudication before the Hon'ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle (SLP No. 31711/2025). The Apex Court had passed an order staying proceedings related to Section 153C. Consequently, the High Court directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C against the petitioners, including giving effect to any impugned orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the present writ petitions is explicitly made subject to the final outcome of SLP No. 31711/2025. No specific finding was made on the merits of the jurisdictional or limitation arguments, as the matter was stayed pending the Supreme Court's decision.