High Court of Andhra Pradesh · Judgments and reasoned final orders
Satya Narayanamurthy Kaki v. The National Faceless Assessment Centre, New Delhi & Ors. (and 6 connected Writ Petitions)
W.P. Nos. 8274, 11241, 13324, 16130 & 23385 of 2024 and W.P. Nos. 185 & 3527 of 2026 ·
Batch of 7 writ petitions challenging reassessment notices and orders for AY 2015-16 initiated after 01.04.2021 allowed and impugned orders set aside following Union of India v. Rajeev Bansal (para 19(f)), Deepak Steel & Power Ltd., and ACIT v. Nehal Ashit Shah.
1. FACTS OF THE CASE
Seven connected writ petitions (W.P. Nos. 8274, 11241, 13324, 16130, and 23385 of 2024 and W.P. Nos. 185 and 3527 of 2026, with Satya Narayanamurthy Kaki v. NFAC & Ors. as the lead petition) challenged reassessment notices and consequential assessment orders for AY 2015-16 initiated pursuant to notices issued on or after 01.04.2021.
2. DISCUSSION BY THE COURT
Relying on the Supreme Court decisions in Union of India v. Rajeev Bansal, (2024) 469 ITR 46 (SC) (paragraph 19(f)), Deepak Steel and Power Ltd. v. CBDT, (2025) 476 ITR 369 (SC), and Assistant Commissioner of Income Tax Circle 19(1) v. Nehal Ashit Shah, 2025 SCC OnLine SC 1755 (as well as Supreme Court order dated 04.05.2026 in SLP(C) No. 2055 of 2025), and recording the fair statement of Junior Standing Counsel for the Department that the issue stood covered by those Supreme Court rulings, the Division Bench held that because the reassessment proceedings for AY 2015-16 were initiated pursuant to notices issued after 01.04.2021, the impugned orders were unsustainable in law.
3. JUDICIAL DECISION
The Andhra Pradesh High Court allowed all seven writ petitions and set aside the impugned orders for AY 2015-16.
4. OUTCOME
In favour of the assessees across all 7 writ petitions; impugned reassessment orders for AY 2015-16 set aside.
5. AKHB REVIEW POINT
AKHB analysis: Cites the three-case Supreme Court trilogy on AY 2015-16 TOLA invalidity — Rajeev Bansal ((2024) 469 ITR 46 (SC)), Deepak Steel & Power Ltd. ((2025) 476 ITR 369 (SC)), and ACIT v. Nehal Ashit Shah (2025 SCC OnLine SC 1755) — confirming that any post-01.04.2021 reassessment initiation for AY 2015-16 must be struck down outright.
Source and verification
Reviewed from the complete 4-page official High Court judgment PDF (20260915_APHC010319992024.pdf, SHA-256: 9c98bf3837a1e9b712977f94fce3a4b2cea564b9b9f86042b805ab807f260ceb).
Original PDF: 4 pages · SHA-256: 9c98bf3837a1e9b712977f94fce3a4b2cea564b9b9f86042b805ab807f260ceb
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Refers to the Income-tax Act, 1961 and allied statutory rules/circulars as applicable to the relevant assessment years.
No subsequent Supreme Court reversal or stay is recorded in the source judgment text.
AI disclosure and professional disclaimer
AI-assisted source review. Independent human approval is not represented.
General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.