JAO and FAO Have Concurrent Power to Start Reassessment under s.148, Supported by Mandate in s.151A

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....The HC held that both the JAO and the FAO possess concurrent jurisdiction to initiate reassessment proceedings under s.148, consistent with statutory mandate in s.151A; co-ordinate bench precedent in the same territorial jurisdiction remains binding notwithstanding an appeal pending before the apex court, subject to the limited carve-out permitting Revenue to continue proceedings with protective directions in prior litigations. The Supreme Court authority relied upon by petitioners does not assist on these specific facts. In consequence, the appeals by the petitioners are devoid of merit and are dismissed, leaving the reassessment proceedings initiated by either JAO or FAO operative within the territorial jurisdiction.....