High Court of Himachal Pradesh · Judgments and reasoned final orders
Saurabh Katoch v. Deputy Commissioner of Income Tax, Central Circle, Shimla & Ors.
CWP No. 1014 of 2026 ·
Writ petition challenging jurisdictional competence of DCIT Central Circle Shimla to issue section 148 notice dated 19.12.2025 for AY 2023-24 disposed of by directing that the matter shall be governed by the pending Supreme Court decision in ACIT v. M/s Dr. Reddy's Laboratories Ltd. (SLP(C) No. 17040/2024) and staying reassessment proceedings in the interim.
1. FACTS OF THE CASE
Saurabh Katoch filed CWP No. 1014 of 2026 challenging the legality, validity, and jurisdiction of a notice dated 19.12.2025 (Annexure P-2) issued under section 148 for AY 2023-24 by the Deputy Commissioner of Income Tax, Central Circle, Shimla and the consequential reassessment proceedings.
2. DISCUSSION BY THE COURT
The Division Bench noted that the identical question regarding the legality and validity of the section 148 notice was already pending consideration before the Supreme Court of India in SLP(C) No. 17040/2024, titled The Assistant Commissioner of Income Tax & Anr. v. M/s Dr. Reddy's Laboratories Ltd. with connected matters. Observing judicial discipline, the Court refrained from expressing a separate opinion on merits, directed that the writ petition shall be governed by the judgment to be rendered by the Supreme Court, and held that allowing proceedings to continue before the competent authority in the meantime would lead to multiplicity of litigation.
3. JUDICIAL DECISION
The Himachal Pradesh High Court disposed of CWP No. 1014 of 2026 by directing that the case shall be governed by the Supreme Court's decision in SLP(C) No. 17040/2024 (ACIT v. M/s Dr. Reddy's Laboratories Ltd.) and staying the reassessment proceedings until the issue is finally decided by the Supreme Court.
4. OUTCOME
Disposed of in terms of pending Supreme Court decision in SLP(C) No. 17040/2024, with reassessment proceedings stayed in the interim.
5. AKHB REVIEW POINT
AKHB analysis: Note the chronological interplay between this January 2026 Himachal Pradesh High Court order (staying JAO-issued section 148 proceedings awaiting the Supreme Court's decision in Dr. Reddy's Laboratories, SLP(C) No. 17040/2024) and the subsequent legislative/judicial developments recorded in the June 2026 Gauhati High Court order in PCIT v. Ram Narayan Sah (I.A.(Civil)/1844/2026).
Source and verification
Reviewed from the complete 3-page official High Court judgment PDF (20260109_HPHC010024392026.pdf, SHA-256: 24f262cb5bcbcb23379d191f92bf2748bb4b857f95fb355456de398ff9273448).
Original PDF: 3 pages · SHA-256: 24f262cb5bcbcb23379d191f92bf2748bb4b857f95fb355456de398ff9273448
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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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.