Mpr Projects Private Limited. Vs Assessment Unit (Telangana High Court)
The Telangana High Court heard a batch of writ petitions filed by several petitioners challenging the initiation of reassessment proceedings under Sections 148A and 148 of the Income Tax Act by the Jurisdictional Assessing Officer (JAO). A large number of counsel appeared for the petitioners, and senior standing counsel represented the Income Tax Department. The petitioners argued that although multiple grounds had been raised in individual cases, the core issue in all petitions had already been decided by a coordinate Bench of the Court in W.P. No. 26304 of 2024, which followed the earlier ruling in Kankanala Ravindra Reddy v. Income Tax Officer. They requested that the present petitions be disposed of similarly by setting aside the proceedings initiated under Sections 148A and 148.
To support their request, the petitioners relied on decisions from several High Courts, including the Bombay, Gauhati, Punjab and Haryana, Telangana, Himachal Pradesh, Gujarat, Jharkhand, Calcutta, Madras, Rajasthan, and Karnataka High Courts. These precedents addressed issues concerning the jurisdiction of the JAO to initiate reassessment proceedings after the introduction of the Faceless Scheme on 29 March 2022 through Notification No. 18 of 2022 under Section 151A of the Act.
