Ajay Mohan Goel, Judge (Oral)

With the consent of the parties, this writ petition is being disposed of today itself.

2. By way of this writ petition, the petitioner has approached this Court, inter alia, praying for the following relief:-

“(a) For the issuance of a writ in the nature of Certiorari and/or any other appropriate writ, order or direction, quashing the notice dated 22.3.2024 (Anneuxre P-4) under Section 151 of the Income Tax Act, approved by respondent No.2, notice dated 26.3.2024 (Annexure P-5) under Section 148 of the Income Tax Act, issued by respondent No.3 notice dated 28.6.2024 (Anneuxre P-6) under Section 144(B) of the Income Tax Act, issued by respondent No.4 notice under Section 142(1) of the Income Tax Act dated 9.9.2024 (Anneuxre P-7) issued by respondent No.4, notice under Section 142(1) of the Income Tax Act dated 11.10.2024 (Anneuxre P-8) by respondent No.4.”

3. The writ petition was disposed of by this Court in terms of order dated 17.09.2025, in the following terms:-

“2. The subject matter of the challenge in this petition, whereby the legality, validity and propriety of impugned notice under Section 148, dated 26.3.2024 (Annexure P- 5) is already under consideration before the Hon’ble Supreme Court of India in SLP (c) No. 17040/2024, titled as The Assistant Commissioner of Income Tax & Another Vs. M/s Dr. Reddy Laboratories Ltd. with connected matters.

3. Since the issue involved in this petition is already pending consideration before the Hon’ble Supreme Court, therefore, keeping in view the judicial discipline, we refrain ourselves from giving our opinion with respect to impugned notice under Section 148, dated 26.3.2024 (Annexure P-5), as assailed in this petition. We direct that the present petition shall be governed by the judgment passed by the Hon’ble Supreme Court and the decision thereto, shall be binding on this case also.

5. The continuity of proceedings before the competent authority, in view of the pendency of the matter before the Hon’ble Supreme Court is bound to lead to multiplicity of litigation. Therefore, we deem it appropriate to stay such proceedings till the time issue is finally decided by the Hon’ble Supreme Court. Ordered accordingly.

6. The petition is disposed of in above terms, so also the pending application(s), if any.”

4. The Hon'ble Supreme Court of India was pleased to dispose of a large batch of reassessment matters in terms of judgment dated 10.04.2026, passed in C.A. No.4716 of 2026, titled as Income Tax Officer Vs. Tej Partap Singh, by observing as under:-

“18. It is urged that, in light of the divergent views taken by the High Courts owing to perceived ambiguity in the existing law, Parliament has now made the clarificatory amendment with retrospective effect from 01.04.2021, the date on which the original provisions came into force, and that the alleged anomalous situation, if any, has been removed. It was additionally submitted that the power to enact retrospective amendments is well settled in law, and that fresh notices will now be issued to assessees in accordance with the clarified position, so that pending reassessment proceedings may be concluded in accordance with law.

19. Conversely, it has been vehemently urged on behalf of the assessees that the new Amendment is not ‘clarificatory’ in nature but is rather an abortive attempt to fasten penal liability retrospectively, which is impermissible under law. It is their contention that the amending laws having antedated civil consequences ought to be construed strictly.

20. In all fairness, we may add that several other contentions have also been raised by both sides, which we do not consider it necessary to advert to at this stage in light of the order we propose to pass. In the facts of the present batch, we are of the considered view that it is not necessary for this Court to examine the merits of the rival submissions concerning the correctness of the impugned judgments or the scope of the