High Court of Judicature for Rajasthan · Judgments and reasoned final orders
M/s. Shiv Vegpro Private Limited v. Deputy/Assistant Commissioner of Income Tax, Kota
D.B. Civil Writ Petition No. 19848/2023 ·
Reassessment challenge under section 148 (interplay with section 153C for searched third-party material): writ petition disposed of in terms of Shyam Sundar Khandelwal & Ors. v. ACIT ((2024) 471 ITR 45 (Raj)).
1. FACTS OF THE CASE
M/s. Shiv Vegpro Private Limited (Kota) filed D.B. Civil Writ Petition No. 19848/2023 challenging reassessment proceedings initiated under section 148 of the Income-tax Act, 1961.
2. DISCUSSION BY THE COURT
Counsel for both parties agreed at the Bar (ad idem) that the controversy was squarely covered by the Division Bench decision of the Rajasthan High Court in Shyam Sundar Khandelwal & Ors. v. Assistant Commissioner of Income Tax ((2024) 471 ITR 45).
3. JUDICIAL DECISION
Disposed of D.B. Civil Writ Petition No. 19848/2023 in the same terms as Shyam Sundar Khandelwal ((2024) 471 ITR 45).
4. OUTCOME
Assessee - Writ petition disposed of in terms of Shyam Sundar Khandelwal & Ors. v. ACIT ((2024) 471 ITR 45 (Raj)).
5. AKHB REVIEW POINT
AKHB analysis: in the Rajasthan High Court, where reassessment for pre-2021 search/seizure material of a third party is initiated under section 148 instead of following the mandatory satisfaction-note procedure of section 153C, Shyam Sundar Khandelwal ((2024) 471 ITR 45) governs.
Source and verification
1-page official High Court of Judicature for Rajasthan judgment PDF (20250127_RJHC021013042023.pdf).
Original PDF: 1 pages · SHA-256: 098fea64f2316a3ffd6230056252eb5e881a22f09fec7ddf7eca43f267b6895a
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies sections 148 and 153C of the Income-tax Act, 1961. Income-tax Act, 2025 equivalence is not verified.
Full primary judgment PDF read page-by-page and verified against the AKHB Google Drive repository. Comprehensive subsequent judicial treatment has not been independently verified.
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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.