Judicial authority determines that proceedings initiated by tax authorities must comply with legal jurisdiction, especially after significant procedural changes.

ORDER :

1. Ms. Akruti Agarwal, Mr. M.Shriraj, learned counsel representing M/s. R.S.Associates, Mr. Kailash Nath P.S.S., Mr. Thanneru Chaitanya Kumar, Mr. Chanda Sumanth, Mr. P.Soma Shekar Reddy, Mr. C.V.Narasimhan, learned counsel representing Mr. Mohd. Mukhairuddin, Mr. B.Krishna Reddy, Mr. A.V.Raghu Ram, Mr. V.Aneesh, Mr. A.V.A.Siva Kartikeya, Mr. Sashank Dundu, learned counsel representing Mr. Dundu Manmohan, Mr. Parikshith Kutur, Mr. S.Vijay Adithya, Mr. Pramod Maligi, Mr. B.Muralidar, learned counsel representing Mr. V.V.S.Ankith, Mr. M.Pranay Sagar, Mr. M.Mehdi Hussain, Ms. Sneha Asthana, Mr. Gopala Rao Amancharla V., Mr. Akshay Mantri, Mr. Chokkapu Neela Achyuth, Mr. Appasani Ram Dheeraj and Ms. P.Praneeta Sri, learned counsel representing Ms. Sheetal Srikanth, learned counsel for the petitioners.

Ms. J.Sunitha, Ms. Bokaro Sapna Reddy, Mr. N.Praveen Reddy, Mr. Vijhay K Punna, Mr. K.Sudhakar Reddy, learned Senior Standing Counsel appears for the Income Tax Department.

Mr. B.Mukherjee, learned counsel representing Mr. N.Bhujanga Rao, learned Deputy Solicitor General of India, appears for Union of India.

2. In all these writ petitions the challenge is to the initiation of proceedings under Sections 148 (A) and 148 of the Income Tax Act, 1961 (for short “the Act”) by the Jurisdictional Assessing Officer (JAO).

3. Petitioners though have taken other pleas in most of these writ petitions, but they submit that the issues involved in the present batch of writ petitions have been considered and settled by the judgment rendered by the learned Coordinate Bench of this Court in W.P.No.26304 of 2024 vide order dated 28.04.2025 following the decision rendered in the case of Kankanala Ravindra Reddy vs. Income Tax Officer, (2023) 156 Taxmann.com 178 (Telangana). It is submitted that the present writ petitions may be disposed of on same lines after setting aside the impugned proceedings under Sections 148 (A) and 148 of the Act and on similar terms as are set out in the case of Kankanala Ravindra Reddy (supra) and also in W.P.No.26304 of 2024, dated 28.04.2025.

4. In support of the submissions made by the learned counsel for the petitioners, they relied on the judgments of the Bombay High Court in Hexaware Technologies Ltd. vs. Assistant Commissioner of Income Tax and others, (2024) 464 ITR 430 (Bom), Abhin Anilkumar Sah vs. Income Tax Officer (International Taxation) and others, (2024) 468 ITR 350 (Bom), Bank of India vs. Assistant Commissioner of Income Tax and others, (2024) 468 ITR 350 (Bom); judgment of Gauhati High Court in Ram Narayan Sah vs. Union of India and others, (2024) 471 ITR 228 (Gauhati) judgment of Punjab and Haryana High Court in Jatinder Singh Bhangu vs. Union of India and others, (2024) 466 ITR 474 (P&H) judgments of Telangana High Court in Venkataramana Reddy Patloola vs. Deputy Commissioner of Income Tax and others, (2023) 468 ITR 181 (Telangana), Shaik Sajid vs. Assessment Unit, Income Tax Department and others, W.P. No. 26885 of 2024, Kings Pride Infra Projects (P) Ltd. vs. Deputy Commissioner of Income Tax, (2025) 176 Taxmann.com 704 (Telangana), Satyaprakash Chigurupati vs. The Assistant Commissioner of Income Tax, Ward 6(1), Hyderabad, W.P. No. 21063 of 2025 and Deloitte Consulting India (P) Ltd. vs. Assessment Unit, Income Tax Department, (2025) 178 Taxmann.com 781 (Telangana) judgment of Himachal Pradesh High Court in Govind Singh vs. Income Tax Officer, (2024) 165 Taxmann.com 113 (Himachal Pradesh), judgment of Gujarat High Court in Mansukhbhai Dahyabhai Radadiya vs. Income Tax Officer, (2024) SCC OnLine Guj 4012, judgment of Jharkhand High Court in Shyam Sunder Saw vs. Union of India and ot