High Court of Judicature at Bombay (Aurangabad Bench) · Judgments and reasoned final orders
Gauri Ganesh Steels, A Partnership Firm Through Its Authorized Partner v. The Director General of Income Tax, Pune & Anr.
Writ Petition No. 567 of 2026 ·
Section 148 notice issued to partnership firm by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.
1. FACTS OF THE CASE
Gauri Ganesh Steels, a partnership firm, filed WP No. 567 of 2026 challenging a section 148 reassessment notice issued by the Jurisdictional Assessing Officer after 29.03.2022.
2. DISCUSSION BY THE COURT
Applying Hexaware Technologies Ltd. v. ACIT, (2024) 162 taxmann.com 225 (Bombay), the Division Bench held that after the promulgation of the faceless reassessment scheme on 29.03.2022, only the Faceless Assessing Officer (FAO) and not the JAO is empowered to issue a notice under section 148.
3. JUDICIAL DECISION
The Court set aside the impugned section 148 notice and all emanating proceedings/orders, reserving liberty to the Revenue to revive the petition by praecipe if the Supreme Court sets aside Hexaware Technologies Ltd.
4. OUTCOME
In favour of the assessee (Gauri Ganesh Steels); section 148 notice set aside.
5. AKHB REVIEW POINT
AKHB analysis: Even where the Director General of Income Tax (Investigation/System) is arrayed as respondent, a JAO-issued section 148 notice post-29.03.2022 is unsustainable in Bombay High Court jurisdiction under Hexaware Technologies Ltd.
Source and verification
Reviewed from the complete 3-page official High Court judgment PDF (20260123_HCBM030525832025.pdf, SHA-256: 2f1aea83644fa3c43e9bacb5baf0a6a2827de225e3e121ee121e59adf29f18d6).
Original PDF: 3 pages · SHA-256: 2f1aea83644fa3c43e9bacb5baf0a6a2827de225e3e121ee121e59adf29f18d6
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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.
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