Stay on Section 148 reassessment over dispute between Jurisdictional and Faceless Assessing Officers under Section 151A

SC considered challenge to reassessment proceedings initiated under Section 148, involving the question whether jurisdiction to initiate such proceedings lies with the Jurisdictional Assessing Officer or the Faceless Assessing Officer in light of Section 151A. HC had held that both possess concurrent jurisdiction and applied the TKS Builders precedent for Delhi. SC did not decide the merits but issued notice and permitted dasti service. Pending further hearing, SC ordered that the assessment proceedings shall remain stayed until the next date of hearing.

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The Supreme Court, in an interlocutory order, entertained the petitioner's challenge and directed that "Issue notice" be served on the respondent, who was unrepresented at this stage. The Court further permitted "Dasti service, in addition, is permitted," allowing the petitioner to effect personal service of notice to expedite proceedings. Crucially, the Court granted interim protection by directing that "the assessment proceedings shall remain stayed till the next date of hearing," thereby preserving the status quo and preventing the continuation of the impugned assessment during the pendency of the Special Leave Petition. The matter was ordered to be "Tag[ged] with SLP(C) No. 29723/2025," indicating that it raises similar or connected issues to be heard together.

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