2026 (7) TMI 430

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....allenged is that the jurisdictional Assessing Officer had no jurisdiction to issue the impugned Notice but it was only the Faceless Assessing Officer who could issue the same. 3. The present Writ Petition came to be allowed and the impugned Notice issued under Section 148 was set aside. Being aggrieved by the decision passed by this Court in the Petitioner's case as well as in a batch of several other Petitions which followed the decision in the Petitioner's case, the Revenue preferred Appeals before the Hon'ble Supreme Court. The Hon'ble Supreme Court, by four separate Orders dated 10th April 2026, 4th May 2026, 15th May 2026 & 15th May 2026 respectively, passed in a batch of matters, remanded the matters back to the respective High Cou....

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....ppeal No. 4716 of 2026 and connected matters. 4. The instant cases were segregated through the abovementioned order on the premise that they may be pertaining to Assessment Year 2015-16. It is fairly conceded by Mr. N. Venkataraman, learned Additional Solicitor General of India, representing the Revenue, that in the assessment cases pertaining to the year 2015-16, the notices issued/proposed to be issued for reassessment would stand barred by time in light of the view taken by this Court in Union of India & Ors. v. Rajeev Bansal, 2024 SCC OnLine SC 2693. 5. There is no quarrel that if the instant cases are found to pertain to Assessment Year 2015-16, then the impugned notices are liable to be struck down outrightly in term....