Dhanwanti Jain Vs ITO (Rajasthan High Court)
The Rajasthan High Court dismissed a writ petition challenging a reassessment notice dated 19.03.2026 issued under Section 148 of the Income Tax Act, 1961 and the sanction note dated 18.03.2026 issued under Section 151. The reassessment was initiated on the basis of information received under the scheme notified under Section 135A concerning an alleged mismatch in the petitioner’s interest income for Assessment Year 2022-23.
The petitioner had filed her return declaring income under different heads. During processing under Section 143(1), the Centralised Processing Centre made adjustments relating to interest income and consequential TDS credit. The petitioner filed a rectification application under Section 154, which was rejected, and thereafter filed an appeal before the Commissioner (Appeals), National Faceless Appeal Centre (NFAC), which was stated to be pending.
During pendency of that appeal, the Assessing Officer issued the Section 148 notice after obtaining approval under Section 151, alleging escapement of income based on information received under Section 135A. The petitioner contended that no mismatch existed because the interest income had already been disclosed in the return. She further alleged that the notice had been issued mechanically without independent application of mind or objective satisfaction and that reassessment on the same issue during pendency of the appeal amounted to parallel proceedings. An objection dated 13.04.2026 was submitted to the Assessing Officer, but was rejected by communication dated 16.04.2026.
