TaxTMI 
TaxTMI 
2026 (5) TMI 1638
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.... a part of a batch of a writ appeals filed under Section 4 of the Karnataka High Court Act, 1961 directed against the learned Single Judge's order dated 24.09.2025 in W.P.No.6120/2024 allowing the writ petition, whereunder the respondent/assessee had challenged the notice(s) issued under Sections 148/148A of the Income Tax Act, 1961 (for short, 'the Act') and/or reassessment order passed under Section 147 of the Act. 2. The above writ appeal is listed on the memo moved by learned counsel for the appellants/Revenue and the matter was taken up for final disposal with the consent of learned counsel appearing for the parties. 3. Learned counsel appearing for the parties bring to the notice of this Court the order passed by the Hon'ble....
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....the IT Act, thereby implying that the "Assessing Officer" for the purposes of Sections 280 and 281 of the Income Tax Act, 2025 shall mean to be an Assessing Officer other than the NFAC or any assessment unit referred to in Section 273(3). The amended Section 279 reads as follows: 71. In section 279 of the Income-tax Act, after sub-section (2), the following sub-section shall be inserted, namely: -- '(3) The "Assessing Officer" for the purposes of sections 280 and 281 shall mean to be an Assessing Officer other than the National Faceless Assessment Centre or any assessment unit referred to in section 273(3).' 17. In this backdrop, where an interpretative issue concerning the older provisions is already under consideration, ....
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....pass. In the facts of the present batch, we are of the considered view that it is not necessary for this Court to examine the merits of the rival submissions concerning the correctness of the impugned judgments or the scope of the competing precedents at this juncture. 21. It appears to us that the assessees would be entitled to challenge the amending provisions as elaborated upon heretofore, for which it would only be appropriate to relegate them to the jurisdictional High Courts. All contentions raised before us, as well as any other grounds available to them to question the impugned notices, may be urged before the High Courts instead. 22. Since the High Courts have primarily quashed the reassessment notices on the grou....
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....posed by the High Courts. 28. The High Courts are requested to decide the matters preferably by 30.09.2026. Learned counsel for the parties undertake to extend full cooperation to the High Courts in this regard. No adjournments may be granted by the High Courts on mere asking of the parties." 4. Learned counsel appearing for the parties seek disposal of the above writ appeal in terms of the order passed by the Hon'ble Apex Court, referred to above. Further, learned counsel appearing for the respondent/assessee seeks liberty to lay challenge to Section 147A of the Act in terms of the liberty granted by the Hon'ble Apex Court. 5. Learned senior counsel Sri. K.K. Chythanya also brings to the notice of this Court, order d....