The jurisdiction of the Assessing Officer to issue notices under the Income Tax Act is annulled if the action violates procedural norms established by recent legislative changes.

ORDER :

S.R. Krishna Kumar, J.

In this petition, petitioner seeks the following reliefs:

"a) Issue a Writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 21.03.2025 passed under section 147 of the Act for the assessment year 2021-22 by the Respondent No 1 bearing DIN and order No.ITBA/AST/S/147/2024-25/1074835439(1) herein marked as Annexure-A1.

b) Issue a writ of Certiorari or direction in the nature of a writ or certiorari quashing the notice of demand issued under Section 156 of the Act dated 21.03.2025 for the Assessment Year 2021-22 by the Respondent No.1 bearing DIN & Notice No.ITBA/AST/S/156/2024-25/1074835548(1) herein marked as Annexure-A2.

c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 21.03.2025 issued under Section 274 r.w.s 270A of the Act for the Assessment Year 2021- 22 by the Respondent No.1 bearing DIN No.ITBA/ PNL/S/270A/2024-25/1074835534(1)herein marked as Annexure-A.3.

d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 02.02.2024 issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1 bearing DIN & Notice No.ITBA/AST/S/148_1/2023-24/ 1060431626(1) herein marked as Annexure-B.

e) Issuing appropriate directions to the learned Commissioner of Income Tax (Appeals) (CIT(A)) i.e., Respondent No.4 in relation to the appeal pending before it for the assessment year 2021-22.

f) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.".

2. Heard learned Counsel for the Petitioner and learned counsel for the respondents and perused the material on record.

3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned Counsel for the petitioner submitted that pursuant to the impugned notices under section 148 of the Income Tax Act, 1961, the respondent No.1 completed the assessment proceedings and passed the Assessment Order for the Assessment year 2021-22 determining the total income of the petitioner as Rs.39,80,750/-.

4. Aggrieved by the said Assessment Order, the petitioner has preferred statutory appeals before the fourth respondent - appellate authority, which is still pending adjudication.

5. Meanwhile, decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, has disposed of the petitions quashing the show cause notice on the ground that the Assessing Officer did not have jurisdiction to issue the notice under section 148 of the Act in the light of Section 151A of the Income Tax Act, 1961 and the Notification pursuant thereto which provided for issuance of notice only by the faceless authority of the respondent. It is therefore submitted that the impugned notice under section 148 of the Act and assessment orders, etc., may be set aside and the present petition be disposed of in terms of the said order. It is also submitted that the necessary directions may be issued to the CIT(A) to dispose of the Appeals, as having become academic/infructuous reserving liberty in favour of the petitioner to seek revival/restoration of the appeal/s if the occasion so arises.

6. Per contra, learned counsel for the respondents - Revenue submits that there is no merit in