The court affirmed that proceedings initiated without jurisdiction under the Income Tax Act by the Assessing Officer post-e-Assessment Scheme are to be quashed, underscoring consistent legal precedents.

ORDER :

Heard learned counsels Sri Dundu Manmohan, Ms. K.Prabhabati representing learned counsel Sri A.V.Raghu Ram, Ms. Pragathi Mandapalle representing learned counsel Ms. Sneha Asthana, Sri P.Soma Shekar Reddy, Sri P.Venkata Prasad representing learned counsel Ms. Velgani Gayatri Priya, Sri Thanneru Chaitanya Kumar, Sri I.Sudhakar Reddy representing learned counsel Ms. Shaik Vaheeda Sushma, Sri Sheetal Srikanth, Sri M.Naga Deepak, Sri A.V.A.Siva Kartikeya, Sri K.Govinda Rao, Sri Santosh Sagar Kapilavai, Sri S.Vijay Adithya, Sri Upadhyay Raghavender, Sri Kailash Nath P.S.S., Ms. Akruti Agarwal, Sri Paturi Rama Krishna and Sri Prudhviraj Mattapally representing learned counsel Sri B.Muralidhar, appearing for the petitioners.

Also heard Ms. J.Sunitha, Ms. Bokaro Sapna Reddy, Sri N.Praveen Reddy, Sri Vijhay K. Punna, Sri K.Sudhakar Reddy, learned Senior Standing Counsels appearing for the Income Tax Department and Sri N.Bhujanga Rao, learned Deputy Solicitor General of India, and learned counsel Sri J.Suresh Babu appearing 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 J atinder 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 & batch 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, Ward 3(3)(5), (2024) SCC OnLine Guj 4012, judgment of Jharkhand High Court in Shyam Sunder Saw vs. Union of India and ot