Jurisdictional challenge to reassessment notice under Section 148 disposed of by following earlier coordinate bench rulings.

A writ petition challenging a Section 148 reassessment notice for assessment year 2020-21 on jurisdictional grounds was disposed of by reference to earlier coordinate bench decisions on the same issue. The petitioner had contended that, under the CBDT circular dated 29.03.2022, the NFAC alone had power to issue such notices, but this order did not independently adjudicate that contention. The challenge therefore did not survive for separate merits consideration, and the connected applications were also disposed of.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for the assessment year 2020-2021 and consequential proceedings were liable to be interfered with on the ground that the issuing authority lacked jurisdiction in view of the CBDT circular dated 29.03.2022.

Analysis: The petition challenged the reassessment notice on the ground of lack of jurisdiction. The stated basis was that, under the CBDT circular/notification dated 29.03.2022, the NFAC had exclusive power to issue notices under Section 148 of the Income-tax Act, 1961. The petition was disposed of in terms of earlier coordinate bench decisions on the same issue.

Conclusion: The challenge was not independently adjudicated in this order and the matter was disposed of by following the coordinate bench rulings, with the effect that the petition did not survive for separate adjudication.

Final Conclusion: The writ petition stood concluded by reference to the earlier decisions on the identical jurisdictional issue, and the connected applications were also disposed of.

Ratio Decidendi: Where a writ petition is disposed of in terms of binding coordinate bench decisions on an identical jurisdictional issue, the same outcome follows without separate merits adjudication in the later order.

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