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The HC upheld the validity of reassessment proceedings initiated under Section 148 of the Act by the Jurisdictional Assessing Officer, holding that both JAO and FAO possess concurrent jurisdiction under the statutory scheme, including Section 151A and the 2022 e-assessment scheme. The HC reaffirmed its earlier ruling in TKS Builders as binding within its territorial jurisdiction, noting that the SC's dismissal of an SLP against a contrary Bombay HC decision, without a reasoned order, does not impliedly overrule or dilute TKS Builders. Pending appeals before the SC were held not to affect the precedential authority of TKS Builders. Consequently, all writ petitions challenging jurisdiction and reopening were dismissed, with no relief granted to the petitioners.
The HC upheld the validity of reassessment proceedings initiated under Section 148 of the Act by the Jurisdictional Assessing Officer, holding that both JAO and FAO possess concurrent jurisdiction under the statutory scheme, including Section 151A and the 2022 e-assessment scheme. The HC reaffirmed its earlier ruling in TKS Builders as binding within its territorial jurisdiction, noting that the SC's dismissal of an SLP against a contrary Bombay HC decision, without a reasoned order, does not impliedly overrule or dilute TKS Builders. Pending appeals before the SC were held not to affect the precedential authority of TKS Builders. Consequently, all writ petitions challenging jurisdiction and reopening were dismissed, with no relief granted to the petitioners.
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