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446 orders · Page 7 of 9
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
The Rajasthan High Court, Jaipur Bench, held that since the narrow compass of the issue concerning Section 153C of the Income Tax Act, 1961, is directly being 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. 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, 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 shall govern the outcome of these petitions. No specific finding was given on the merits of the Section 153C proceedings themselves, 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, 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, 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, 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, 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 as granted by the Apex Court. The 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 Hon'ble Apex Court remains in operation. The outcome of the said 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 deferred pending the Apex Court's decision.
The High Court, acknowledging that the core issue concerning Section 153C of the Income Tax Act, 1961, is under adjudication before the Hon'ble Apex Court in SLP No. 31711/2025, decided 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 present petitions is explicitly made subject to the final outcome of SLP No. 31711/2025. No specific finding was made on the merits of the petitioners' claims regarding jurisdiction or limitation, as the matter was deferred 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. 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 with any consequential 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 case as the matter was stayed by the Apex Court.
The Rajasthan High Court, Jaipur Bench, held that since the core 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 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 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 would 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, 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 SLP No. 31711/2025, decided 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 made on the merits of the Section 153C proceedings themselves, 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 present writ petitions. The 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 Hon'ble Apex Court remains in operation. The outcome of the SLP is stated 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, while considering the submissions, noted that 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 light of the interim protection granted by the Apex Court in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025), the High Court found it appropriate to extend the same protection to the petitioners. 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, 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 the SLP was declared to govern the outcome of these writ petitions. No specific finding was given on the merits of the Section 153C proceedings or the Objection Disposal Order.
The Rajasthan High Court, Jaipur Bench, acknowledged 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. The Apex Court had, in that case, stayed proceedings before the Adjudicating Authority concerning Section 153C. Consequently, the High Court found it appropriate to extend the same protection to the petitioners in 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, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The outcome of the present petitions was explicitly made subject to the final outcome of SLP No. 31711/2025.
The Rajasthan High Court held that since the narrow compass of the issue, specifically concerning Section 153C of the Income Tax Act, 1961, was directly under adjudication by the Hon'ble Apex Court in Siddharth Totuka (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. 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, 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 the SLP was declared to govern the outcome of these writ petitions. No specific issue was left undecided, as the court deferred to the Apex Court's decision.
The Rajasthan High Court, 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, decided 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, nor give effect to any impugned orders or consequential orders, for as long as the interim protection granted by the Hon'ble Apex Court remains in operation. The ultimate outcome of these writ petitions is made contingent upon the final decision in SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025). No specific finding was made on the merits of the jurisdictional or limitation arguments.
The Rajasthan High Court, Jaipur Bench, observed that 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 the case of Siddharth Totuka. The Court noted that the Apex Court had granted interim protection by staying proceedings under Section 153C. Therefore, the High Court deemed it 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 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 the SLP filed by Siddharth Totuka was stated to govern the outcome of these petitions.
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 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 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) was stated to govern the outcome of the present petitions. No specific finding was given on the merits of the jurisdictional or limitation arguments, as the matter was stayed pending the Supreme Court's decision.
The High Court allowed the writ petition, quashing and setting aside the notice dated March 30, 2025, issued by the Jurisdictional Assessing Officer (JAO) and all consequential orders. The Court held that the mandate of Section 151A of the Income Tax Act, 1961, must be strictly followed, and JAOs do not have the jurisdiction to issue notices under Section 148 of the Act, as this weakens Section 151A and may lead to its diminishing activation. Adherence to the algorithm-based random assessing system is required for assessment and reassessment under Sections 147, 148, and 148A, in light of the sanction under Section 151A. The Court relied on its previous decision in Sharda Devi Chhajer & Anr. Vs The Income Tax Officer & Anr. and another order by one of its judges in Jasjit Singh vs. Union of India & Ors. The time spent during the pendency of the litigation was to be excluded for computing the limitation for issuing fresh notices, if needed, in compliance with CBDT Notification dated March 29, 2022, keeping the Faceless Assessing Officer (FAO) as the assessing officer. The subsequent order dated November 28, 2025, and all consequential orders were also set aside as the show cause notice was held to be bad.
The Tribunal held that jurisdiction vests exclusively with the Faceless Assessing Officer. Accordingly, as long as the judgments in Sharda Devi Chhajer and Hexaware Technologies Ltd. continue to hold the field, notices issued by the Jurisdictional Assessing Officer are legally unsustainable. The impugned notice dated 30.08.2024 issued under Section 148 of the Income Tax Act, 1961, for A.Y. 2020-2021, along with all consequential proceedings, were quashed for lack of jurisdiction. Liberty was granted to the Revenue to initiate proceedings afresh through the Faceless Assessing Officer, subject to compliance with limitation and other legal requirements. It was further clarified that if the Supreme Court reverses, sets aside, or materially modifies the judgments in Hexaware Technologies Ltd. and Sharda Devi Chhajer, the Revenue would be at liberty to act afresh in accordance thereof. The petitioner stated that other grounds were not pressed at this stage.
The Tribunal held that jurisdiction vests exclusively with the Faceless Assessing Officer. Accordingly, as long as the judgments in Sharda Devi Chhajer and Hexaware Technologies Ltd. continue to hold the field, notices issued by the Jurisdictional Assessing Officer are legally unsustainable. The impugned notice dated 30.08.2024 issued under Section 148 of the Income Tax Act, 1961, for A.Y. 2019-2020, along with all consequential proceedings, were quashed for lack of jurisdiction. Liberty was granted to the Revenue to initiate proceedings afresh through the Faceless Assessing Officer, in accordance with law and subject to limitation and other legal requirements. It was further clarified that if the judgments in Hexaware Technologies Ltd. and Sharda Devi Chhajer are reversed, set aside, or materially modified by the Supreme Court, the Revenue would be at liberty to act accordingly. The petitioner stated that other grounds were not pressed at this stage.
The Tribunal held that notices issued by the Jurisdictional Assessing Officer, instead of the Faceless Assessing Officer, are without jurisdiction and legally unsustainable. This decision was based on the respectful agreement with the views taken by the Division Bench of the Rajasthan High Court in Sharda Devi Chhajer (supra) and the Bombay High Court in Hexaware Technologies Ltd. (supra), which established that jurisdiction vests exclusively with the Faceless Assessing Officer. Consequently, the impugned notice dated 27.08.2024 issued under Section 148 of the Income Tax Act, 1961, for A.Y. 2023-2024, along with all consequential proceedings, were quashed for lack of jurisdiction. Liberty was granted to the Revenue to initiate proceedings afresh through the Faceless Assessing Officer, subject to legal requirements. The Revenue was also granted liberty to act in accordance with any reversal or material modification of the cited judgments by the Supreme Court. The petitioner stated that other grounds were not pressed at this stage.
The Tribunal, in respectful agreement with the Division Bench of the Rajasthan High Court in Sharda Devi Chhajer (supra) and the Bombay High Court in Hexaware Technologies Ltd. (supra), held that jurisdiction vests exclusively with the Faceless Assessing Officer. Therefore, as long as these judgments hold, notices issued by the Jurisdictional Assessing Officer are legally unsustainable. Consequently, the impugned notice dated 27.08.2024 issued under Section 148 of the Income Tax Act, 1961, for A.Y. 2022-2023, along with all consequential proceedings, were quashed for lack of jurisdiction. The Revenue was granted liberty to initiate proceedings afresh through the Faceless Assessing Officer, subject to compliance with limitation and other legal requirements. It was further clarified that if the judgments in Hexaware Technologies Ltd. and Sharda Devi Chhajer are reversed or materially modified by the Hon'ble Supreme Court, the Revenue shall be at liberty to act accordingly. The petitioner stated that other grounds were not pressed at this stage.
The Tribunal, in respectful agreement with the Division Bench of the High Court in Sharda Devi Chhajer (supra) and the Bombay High Court in Hexaware Technologies Ltd. (supra), held that jurisdiction vests exclusively with the Faceless Assessing Officer. Consequently, as long as these judgments remain in effect, notices issued by the Jurisdictional Assessing Officer are legally unsustainable. The impugned notice dated 30.08.2024 issued under Section 148 of the Income Tax Act, 1961, for A.Y. 2017-2018, along with all consequential proceedings, were quashed for lack of jurisdiction. Liberty was granted to the Revenue to initiate proceedings afresh through the Faceless Assessing Officer, in accordance with law and subject to statutory compliance and limitation. The Revenue was also granted liberty to act afresh if the judgments in Hexaware Technologies Ltd. and Sharda Devi Chhajer were reversed, set aside, or materially modified by the Supreme Court. The petitioner stated that other grounds raised were not pressed at this stage.