With the consent of the parties, this writ petition is bheing 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) That this Hon’ble Court may be pleased to issue writ in the nature of certiorari for quashing of Notice dated 28.03.2025 (Annexure P-2) issued under Section 148 by Respondent No.2 being illegal and without jurisdiction as after the introduction of Notification dated 29.03.2022 (Annexure P-5), the proceedings under Section 148 could have only been initiated by Respondent No.4 and also for the reason that the proceedings in question have been initiated in contravention to the provisions of Section 148A and are based upon presumptions and conjectures without considering the documents on the record.”

1 Whether reporters of the local papers may be allowed to see the judgment?

3. The writ petition was disposed of by this Court in terms of order dated 23.06.2025, in the following terms:-

“.3. The subject matter of the challenge in this petition, whereby the legality, validity and propri.ety of impugned notice under Section 148, dated 28.3.2025 (Annexure P- 2) is already under considera tion before the Hon’ble Supreme Court of Indiaf in SLP (c) Diary No. 17041/2024., case titoled Union of India & Ors. Vs. Association of Tech nical Textiles Manufacturers and Processors & Anrt.

4. Since the rissue involved in this petition is already pending uconsideration before the Hon’ble Supreme Court, therefore, keeping in view the judicial discipline, we refrain ourselves from giving our opinion with respect Cto impugned notice under Section 148, dated28.03.2025 (Annexure P-2), 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 g the decision thereto, shall be binding on this case also.

5. The continuity of proceedings before the competent H 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 ambiguit.y in the existing law, Parliament has now made thPe clarificatory amendment with retrospective effect from 01.04.2021, the date on which the original proHvisions came into force, and that the alleged anomalous situation, if any, has been removed. It was additio nally submitted that the power to enact retrospectivef amendments is well settled in law, and that fresh notices will now be issued to assessees in accord ance with the clarified position, so that pending treassessment proceedings may be concluded in accordance with law.

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

20. In all fairness, we may add that several other i contentions have also been raised by both sides, which H 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