High Court Rejects Income Tax Notice Challenge

Authority: High Court

Order Date: 21 July 2025

Case Overview

• Petitioner: Jatinder Gupta filed a writ petition challenging a notice dated 26 March 2025 issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2021‑22.
• Respondents: Deputy Commissioner, Income Tax and the Income Tax Department.
• Grounds of Challenge: The petitioner contended that the issuing authority lacked jurisdiction because the Central Board of Direct Taxes (CBDT) circular dated 29 March 2022 expressly reserves the power to issue Section 148 notices to the National Faceless Assessment Centre (NFAC).
• Legal References: The Court considered the statutory provisions, the CBDT circular, and earlier judgments – Jatinder Singh Bhangu (19 Jul 2024) and Jasjit Singh (29 Jul 2024) – which dealt with the same jurisdictional issue.

Final Outcome

• The writ petition is dismissed; the Section 148 notice issued on 26 Mar 2025 remains valid.
• All pending applications related to the same matter are also disposed of in accordance with the cited precedents.

Topics: Tax Notice Jurisdiction, NFAC Authority, CBDT Circular