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2025 Supreme(Online)(Chh) 9595

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Deepak Kumar Tiwari, J
Pankaj Kumar Agrawal – Appellant
Versus
Union Of India Through Ministry Of Finance – Respondent


Advocates:
For the Appellants/Petitioners: Mr. Siddharth Dubey, Mr. Ajay Kumrani
For the Respondents: N/A

Table of Content
1. challenge to reassessment process under provisions of income tax act. (Para 2)
2. jurisdictional implications of improper notice issuance. (Para 3 , 4)
3. court's view on jurisdiction and authority in reassessment. (Para 5 , 6)
4. disposal and right to appeal upheld. (Para 7 , 8 , 9)

Order on Board

31/07/2025

1. This petition under Article 226 of the Constitution of India has been filed for the following relief(s) :

10.1 Quashing/setting aside Annexure “P1A” i.e. reassessment order dated 21.3.2025 and consequential demand notice dated 21.03.2025, 10.2 Quashing/setting aside Annexure “P/1B” i.e. notice issued under Section 148 of the Act triggering/initiating reassessment proceeding.

10.3 Quashing/setting aside Annexure “P/1C” i.e.

approval issued under Section 151 of the Act.

10.4 Grant any other relief(s) and/or pass any such order(s) that this Hon’ble Court may deem fit in facts and circumstances of the case.”

2. Necessary facts of the case are that approval under Section

151 of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), was granted by the Additional/Joint Commissioner of Income Tax on 28.03.2024 for reassessment in respect of the Assessment Year

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