The Associated Journals Ltd. Thru. Auth. Representative Mr. Sanjeev Kumar v. Asst. Commissioner Of Income Tax Lko And 2 Others

1. Facts of the case

The company challenged 148 A(b)/148 notices and alleged nonconsideration of its 148 A(c)reply. Revenue objected that the company participated after 29 March 2023 notices and only filed inDecember 2024.

Source: PDF pp.1, 2

2. Discussion by the Hon’ble Court

The Court recorded the issue of jurisdictional officer versus automated allocation under the 29 March 2022 Section 151 A notification and competing High Court authorities, without resolving them.

Source: PDF pp.1, 2

3. Judicial decision

Put up 8 January 2025 as fresh.

Source: PDF p.2

4. Outcome / in whose favour

The jurisdiction challenge remained pending; no stay or final legal conclusion followed.

Source: PDF p.2

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings. Subsequent treatment and current-law applicability have not been verified.

The jurisdiction question was framed, not answered

Associated Journals raised whether Sections 148A(b) and 148 notices could issue from the jurisdictional assessing authority or required an officer assigned through automated allocation under the 29 March 2022 Section 151A notification. The order records reliance on Hexaware Technologies, T.K.S. Builders and a Madras decision, but does not choose between them.

Source: PDF p.1 · PDF p.2 · PDF pp.1–2, complete supplied order

Participation and reply consideration were separate issues

Revenue objected that notices dated 29 March 2023 were followed by participation and a writ only in December 2024. The petitioner also alleged failure to consider its Section 148A(c) reply. Those are recorded positions, not findings of waiver, delay barring relief or a proved failure of consideration.

Source: PDF p.1 · PDF p.2 · PDF pp.1–2, complete supplied order

The operative order was a fresh listing

The matter was put up on 8 January 2025. No stay or final jurisdictional ruling appears in this 3 January order. Later orders in the same writ may have different effects, so the date is essential when using the record; this source does not establish current treatment of the competing authorities.

Source: PDF p.1 · PDF p.2 · PDF pp.1–2, complete supplied order