Jurisdictional challenge to reassessment notice under Section 148 followed earlier coordinate Bench rulings and was disposed of on the same terms.

A challenge to a reassessment notice under Section 148, together with the consequential assessment and demand, was raised on the ground that the issuing authority lacked jurisdiction in light of a CBDT circular and earlier coordinate Bench rulings. The issue was treated as covered by those prior decisions, and the Revenue did not dispute that position. The HC followed the earlier rulings and disposed of the writ petition on the same terms, effectively accepting the jurisdictional challenge.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 and the consequential assessment and demand actions for the relevant assessment year were liable to be interfered with on the ground of want of jurisdiction in view of the CBDT circular and the earlier coordinate Bench decisions.

Analysis: The challenge centered on the competence of the issuing authority to initiate reassessment proceedings. The petition was stated to be covered by earlier coordinate Bench decisions on the same issue, and the revenue did not dispute that position. The Court, therefore, followed the earlier decisions and disposed of the writ petition in the same terms.

Conclusion: The challenge was accepted in line with the earlier decisions, and the petition was disposed of accordingly.

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