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of <h1>Section 148(A)(d) Orders Quashed; Petitioner Allowed Fresh Objections Within Four Weeks Following SC Guidelines</h1> <h3>Rajeev Yadav Versus Assistant Commissioner Income Tax And 2 Others</h3> Rajeev Yadav Versus Assistant Commissioner Income Tax And 2 Others - 2025:AHC:133857 - DB The Allahabad High Court addressed a petition challenging the rejection of objections to reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961, pursuant to orders under Section 148A(d). The Court noted the Supreme Court's rulings in Union of India vs. Rajeev Bansal (2024) and Union of India vs. Ashish Agarwal (2022), which conclusively determined the validity of notices issued under Section 148 between April 1, 2021, and June 30, 2021. Relying on these precedents, the Court quashed and set aside the impugned orders under Section 148A(d) and any consequential proceedings. The Assessing Officer was directed to permit the petitioner to file fresh objections within four weeks, including jurisdictional challenges and reliance on other Apex Court judgments, followed by a hearing and disposal of objections in accordance with law as laid down in the cited Supreme Court decisions. The petitioner was expressly allowed to pursue all legal remedies except on issues conclusively settled by Ashish Agarwal and Rajeev Bansal. Additionally, the Court clarified that the Supreme Court's observations regarding time-barred orders under Section 148A(d) in Rajeev Bansal paragraphs 112-114 would apply. The writ petition was disposed of with these directions, emphasizing adherence to the Supreme Court's authoritative rulings on reassessment notices and procedural compliance under the Income Tax Act.
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