High Court of Judicature at Bombay (Aurangabad Bench) · Judgments and reasoned final orders
S.R. Insurance Services Through Its Partner Ravindra Jamnadas Soni v. Income Tax Officer, Ward 2 & Anr.
Writ Petition No. 177 of 2026 ·
Partnership firm's challenge to JAO-issued section 148 notice allowed following Hexaware Technologies Ltd.
1. FACTS OF THE CASE
S.R. Insurance Services, a partnership firm acting through its partner Ravindra Jamnadas Soni, filed WP No. 177 of 2026 challenging a section 148 notice issued by the Jurisdictional Assessing Officer (ITO Ward 2) after the promulgation of the faceless reassessment scheme on 29.03.2022.
2. DISCUSSION BY THE COURT
Rejecting the Revenue's reliance on T.K.S. Builders Pvt. Ltd. (Delhi HC), the Division Bench applied Hexaware Technologies Ltd. v. ACIT, (2024) 162 taxmann.com 225 (Bombay), holding that only the Faceless Assessing Officer (FAO) has jurisdiction to issue a notice under section 148 after 29.03.2022.
3. JUDICIAL DECISION
The Court set aside the impugned section 148 notice and all consequential proceedings/orders, subject to praecipe revival liberty for the Revenue contingent on the Supreme Court's decision in Hexaware Technologies Ltd.
4. OUTCOME
In favour of the assessee (S.R. Insurance Services); section 148 notice quashed.
5. AKHB REVIEW POINT
AKHB analysis: Partnership firms challenging JAO-issued section 148 notices before the Bombay High Court obtain immediate quashing of both the notice and consequential orders under Hexaware Technologies Ltd., while keeping all other substantive grounds open.
Source and verification
Reviewed from the complete 3-page official High Court judgment PDF (20260123_HCBM030455362025.pdf, SHA-256: 81fbda5464d9c9ddbfda274d84c28c57f98b27e62dc9466e43eb6af975d2d1fd).
Original PDF: 3 pages · SHA-256: 81fbda5464d9c9ddbfda274d84c28c57f98b27e62dc9466e43eb6af975d2d1fd
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.
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