Mandatory time-bound remand directions must be obeyed; later show-cause notices issued without extension are liable to be quashed.

A remand order that fixes a mandatory 12-week period for completion of proceedings must be complied with strictly, and the authority cannot continue the matter by issuing fresh notices after that period without first seeking extension of time. The Gujarat HC treated the later show-cause notices as unsustainable because no final order was passed within the court-prescribed period and no extension application was filed. On that basis, the notices were quashed and the proceedings were not permitted to proceed in breach of the earlier judicial direction.

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Issues: Whether the show-cause notices issued after expiry of the 12-week period fixed by the Court in the earlier remand order were liable to be quashed for non-compliance with the Court's directions.

Analysis: The earlier order had quashed the penalty order under Section 271D of the Income-tax Act, 1961 and remanded the matter to the Assessing Officer with a specific direction to complete the exercise within 12 weeks from receipt of the order. The record showed that no final order was passed within that period, and no application seeking extension of time was filed. In these circumstances, the subsequent show-cause notices could not be sustained, as the authorities had failed to comply with the time-bound judicial direction.

Conclusion: The show-cause notices dated 27.10.2025 and 13.02.2026 were quashed and set aside, and the petition was allowed.

Ratio Decidendi: Where a remand order fixes a mandatory time limit for completion of proceedings and the authority fails to act within that period without seeking extension, subsequent notices issued in the purported continuation of those proceedings are liable to be quashed for breach of the Court's directions.

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