Govind Singh v. Income Tax Officer and others

1. Facts of the case

In CMP 20202/2026, the Court considered revival of CWP 6448/2024 after its disposal dated 25 June 2025. The appearances identify the taxpayer as petitioner/non-applicant, counsel for respondents Nos.1 to3 and separate counsel for respondent No.4, Union of India. The respondents are not expressly labelled applicants. The source identifies the Supreme Court order dated 10 April 2026 in Income Tax Officer v. Tej Partap Singh, Civil Appeal 4716/2026, as Annexure A-2. It does not reproduce the earlier disposal’s reasons or the impugned notices.

Source: PDF p.1

2. Discussion by the Hon’ble Court

For the reasons stated in the application and in view of the identified Supreme Court order, the Court recalled the earlier disposal and restored the writ and applications to their original status and number. In CMP 10902/2025, it reproduced paragraph 27 of the Supreme Court order and extended the stated interim protection in this case.

Source: PDF pp.1–2

3. Judicial decision

The 25 June 2025 disposal was recalled and CWP 6448/2024 revived with its applications. Reply was directed within two weeks and a rejoinder within two weeks thereafter and consideration was listed for 17 August 2026. The Court extended the reproduced interim protection and disposed of CMP 20202/2026 and CMP 10902/2025.

Source: PDF pp.1–2

4. Outcome / in whose favour

The writ was restored for adjudication with the stated interim protection. The source does not finally allow its tax grounds, quash the impugned notices, determine taxable income or order a refund.

Source: PDF pp.1–2

5. Expert Comments

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

Preserve the exact restoration and interim-application identities

The operative recall concerns CMP 20202/2026, the earlier disposal dated 25 June 2025 and the original CWP 6448/2024. The interim application is CMP 10902/2025. These identifiers distinguish this matter from other orders applying the same Supreme Court direction. The Court restores the existing writ and its applications; disposing of the recall and interim applications does not amount to finally disposing of the restored writ. The source gives no basis to create another petition number or to merge this taxpayer with a different same-date case. The interim application is printed as CMP10902/2025 even though the writ is numbered in2024. That printed application year is retained, without silently changing it to2024.

Source: PDF pp.1–2 · PDF pp.1–2

The reproduced protection remains tied to the impugned notices and pending writ

The High Court extends paragraph 27’s protection concerning further assessment/reassessment proceedings pursuant to the impugned notices during the pendency of the writ petitions, subject to High Court terms and conditions. This sheet prints assessment/reassessment; its actual wording is retained rather than replacing it with the repeated reassessment wording found in some other supplied sheets. The direction is interim and source-specific, not a final annulment of the notices or a prediction of how the writ will ultimately be decided.

Source: PDF pp.1–2 · PDF pp.1–2

The two-week reply and two-week rejoinder directions are source-specific

The Court grants two weeks for the reply and two weeks for a rejoinder thereafter. This source does not record a reply already filed. The separate periods must be preserved; neither a four-week reply period nor the reply-filed status from other restoration orders can be substituted. The source does not establish whether later pleadings were filed. The listing date is 17 August 2026. These are historical directions in this particular writ; the source does not establish later compliance, the listed hearing’s result or a new period beginning with publication of this note.

Source: PDF p.1 · PDF p.1

The recorded applicant roles and source limits matter

The appearances identify the taxpayer as petitioner/non-applicant, counsel for respondents Nos.1 to3 and separate counsel for respondent No.4, Union of India. The respondents are not expressly labelled applicants. The note does not infer a different applicant label from related restoration sheets. The Court identifies the 10 April 2026 Supreme Court order in Civil Appeal 4716/2026 and applies the reproduced paragraph. This note does not represent an independent review of the complete Supreme Court judgment, the application annexures or subsequent treatment. The coram is Vivek Singh Thakur and Ranjan Sharma.

Source: PDF pp.1–2 · PDF pp.1–2