Income Tax Assessing Officer & Ors. Vs Gayatri Snehal Rao (Supreme Court of India)
The Special Leave Petition before the Supreme Court challenged the order dated 14th October 2024 passed by the Gujarat High Court in R/Special Civil Application Nos. 5835 of 2024 and 5870 of 2024. There was a delay of 360 days in filing the petition.
Counsel for the petitioners fairly submitted that the common High Court order, insofar as it related to Special Civil Application No. 5870 of 2024, had already been considered by the Supreme Court in Civil Appeal No. 197 of 2026, where directions were clarified regarding changes to be made in the software. In view of the directions already issued in that matter, the Supreme Court held that no further order was required in the present petition. The Special Leave Petition was dismissed both on delay and on merits. Pending applications, if any, were also disposed of.
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High Court Proceedings and Findings
Before the Gujarat High Court, the petitioners challenged intimations issued under Section 143(1) of the Income Tax Act, 1961 for Assessment Years 2020-21 and 2021-22. The intimations were also treated as notices of demand under Section 156(3) of the Act. The High Court initially issued notice and stayed the impugned demand notices.
