This compilation indexes 12 income-tax rulings — spanning ITAT benches at Jodhpur, Lucknow, Vizag, Hyderabad, and Chennai, as well as the Rajasthan High Court at Jodhpur — decided between November 2025 and March 2026. Each ruling engages Section 132A (requisition of books of account or assets) alongside connected provisions such as Section 153A (assessment in search cases), Section 148 (reassessment notice), and Section 151A (faceless scheme for reassessment). The compilation is organised by case index for ease of citation-checking and cross-referencing within legal research workflows. It is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point before pulling full judgments.

Research index only. This page is a structured case-law reference, not legal or tax advice. Every entry must be verified against the full, authoritative judgment text before reliance.

The statutory framework in one paragraph

Section 132A of the Income Tax Act, 1961 empowers the Principal Director General or Director General, Principal Director or Director, Principal Chief Commissioner or Chief Commissioner, or Principal Commissioner or Commissioner to authorise any Joint Director, Joint Commissioner, Assistant Director, Deputy Director, Assistant Commissioner, or Deputy Commissioner to require the delivery of books of account, documents, or assets from any officer, court, or authority having possession or control of them, where the authorising officer has reason to believe that such assets or books represent undisclosed income or property. The provision is distinct from Section 132 (search and seizure), though both sections frequently appear together in search-related assessments governed by Section 153A and the associated time-limit provision in Section 153B.

The 12 rulings

1. Suresh Kumar Sanghvi,Banswara vs DCIT, Central Circle-1 Udaipur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 25 March 2026
Sections engaged: 132, 132A, 139, 153A, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Jodhpur as ITA Nos. 862, 863, and 866/Jodh/2024 covering Assessment Years 2014-15, 2015-16, and 2016-17, with ITA No. 862/Jodh/2024 taken as the lead case. Per the source preview, the three appeals were heard together and disposed of by a consolidated order, as the sole common issue challenged was the levy of penalty under a penalty provision on identical facts across all three years; the assessee contended that the first appellate authority had not appreciated the relevant submissions.

2. Rajesh Kumar Agarwal ,Kanpur vs DCIT, , Kanpur

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 5 January 2026
Sections engaged: 132, 132A, 133A, 153A, 153C, 68, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as I.T.(SS)A. No. 82/Lkw/2022 for Assessment Year 2014-15 (PAN: AEAPA1394M), was filed against the CIT(A) order dated 15/02/2022. Per the source preview, a ground raised by the assessee was that the CIT(A) failed to appreciate that the assessee had duly discharged the onus of proving the three vital ingredients of the relevant unexplained-cash-credits provision — identity, creditworthiness, and genuineness — in respect of an unsecured loan of Rs. 45,00,000/- obtained from Successs Vyapar Ltd., along with supporting documentary evidence placed on record.

3. Vikram Brahmendra Satyajit vs Income Tax Officer, Ward-3(1)

Bench: Income Tax Appellate Tribunal - Vizag
Date: 19 December 2025
Sections engaged: 115W, 120(3), 124(3), 132, 132A, 139, 142, 143, 144(b), 147, 148, 148A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 534/Viz/2025 for Assessment Year 2020-21 (PAN: AONPM1893G), arose from reassessment proceedings initiated after the Assessing Officer noted that the assessee had not filed a return of income despite carrying out substantial cash transactions during the subject year — including interest income from HDFC Bank Ltd of Rs. 67,659/-, cash deposits in a Kotak Mahindra Bank Limited account of Rs. 15,11,000/-, and purchase of immovable property (as per SRO, Patamata) of Rs. 56,58,000/-. The AO accordingly initiated proceedings under Section 148A of the Act and thereafter issued a notice under Section 148, dated 23/03/2024, in response to which the assessee filed a return of income.

4. Deputy Commissioner Of Income Tax vs Subramaniam Kathiresan, Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 18 December 2025
Sections engaged: 132, 132A, 139, 143(3), 153, 153A, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal, registered as ITA No. 899/Chny/2025 for Assessment Year 2014-15 (PAN: AEEPK 6913 N), was preferred by the Revenue against the order of the CIT(A), Chennai-19, dated 17.01.2025. Per the source preview, the matter arose in the context of a search, with the preview referencing documents and annexures found and seized during the course of the search; the substantive grounds are not fully detailed in the available preview.

5. Sangeeta Aggarwal vs Additional Commissioner Of Income Tax

Bench: Rajasthan High Court - Jodhpur
Date: 18 December 2025
Sections engaged: 132, 132A, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 24682/2025 before the Rajasthan High Court challenging a notice dated 24th June 2025 issued under Section 148 for AY 2020-21. Per the source preview, one of the grounds raised was that the notice had been issued by the Jurisdictional Assessing Officer (JAO) rather than a Faceless Assessing Officer (FAO), engaging the question of whether the e-assessment scheme notification of 29th March 2022 applies to search and requisition cases under Sections 132 and 132A.

6. Laxmi Venkata Krishna Rice vs ITO, Ward-1, Suryapet

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 17 December 2025
Sections engaged: 132, 132A, 133A, 139, 142(1), 147, 148, 148A, 148A(d), 151, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as I.T.A. No. 1700/Hyd/2025 for Assessment Year 2017-18 (PAN: AAEFL6494M), was filed by the assessee firm against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 01/08/2025. Per the source preview, the NFAC order in turn arose from the Assessing Officer's order passed under Section 147 read with Sections 144 and 144B of the Act, dated 16/03/2023, for AY 2017-18; the assessee assailed that impugned order before the Tribunal.

7. Vidya Devi vs Principal Commissioner Of Income Tax-1

Bench: Rajasthan High Court - Jodhpur
Date: 17 December 2025
Sections engaged: 132, 132A, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 24668/2025 before the Rajasthan High Court. Per the source preview, counsel for the petitioner submitted that the controversy was squarely covered by the judgment dated 24.09.2025 of the co-ordinate Bench in Jaskaran Singh Brar vs. Principle Commissioner of Income Tax (Central) Jaipur & Ors. (D.B. Civil Writ Petition No. 18987/2025), which in turn had relied on a Gujarat High Court holding that the notification dated 29th March 2022 prescribing the e-assessment scheme does not cover cases where a notice under Section 148 is issued by the JAO on information received in search or requisition proceedings under Sections 132 or 132A.

8. Deepa Ram vs The Deputy Commisioner Of Income Tax

Bench: Rajasthan High Court - Jodhpur
Date: 3 December 2025
Sections engaged: 132, 132A, 147, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 23485/2025 challenging a notice dated 24th March 2024 issued under Section 148 and an assessment order dated 17th March 2025 passed under Section 147. Per the source preview, a primary ground was that the notice had been issued by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO); counsel relied on earlier Rajasthan High Court decisions in Shree Cement Limited vs. ACIT (D.B. Civil Writ Petition No. 10540/2024, dated 05.08.2025) and Sharda Devi Chhajer vs. ITO (2025 SCCOnLine Raj 3386), which had followed a Bombay High Court judgment, in support of the petitioner's position.

9. Ashok Jethwani vs Principal Commissioner Of Income Tax

Bench: Rajasthan High Court - Jodhpur
Date: 27 November 2025
Sections engaged: 132, 132A, 147, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 23230/2025 challenging a notice dated 27.03.2024 issued under Section 148 and an assessment order dated 16.03.2025 passed under Section 147. Per the source preview, the petitioner was aggrieved by both the notice and the assessment order and the matter was listed before the Rajasthan High Court at Jodhpur; the full substantive reasoning is not captured in the available preview.

10. Mani Ram vs Principal Commissioner Of Income Tax

Bench: Rajasthan High Court - Jodhpur
Date: 25 November 2025
Sections engaged: 132, 132A, 147, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 22890/2025 challenging a notice dated 24th March 2024 issued under Section 148 and an assessment order dated 12th March 2025 passed under Section 147. Per the source preview, one of the grounds taken was that the notice had been issued by the Jurisdictional Assessing Officer (JAO) rather than a Faceless Assessing Officer (FAO), raising the same jurisdictional question on the applicability of the e-assessment scheme to search and requisition cases that recurs across several of the Rajasthan High Court matters in this compilation.

11. Shri Sandeep Singhvi vs Income-Tax Officer

Bench: Rajasthan High Court - Jodhpur
Date: 21 November 2025
Sections engaged: 132, 132A, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 22618/2025 before the Rajasthan High Court. Per the source preview, counsel submitted at the outset that the issue was no longer res integra, relying on the judgment in D.B. Civil Writ Petition No. 19953/2025 (Ravindra Singh vs. Principal Commissioner of Income Tax (Central), Jaipur & Ors.), which had in turn relied on the Jaskaran Singh Brar judgment (D.B. Civil Writ Petition No. 18987/2025); in that earlier matter, the reassessment proceedings initiated in respect of search cases were quashed and set aside.

12. Rishabh Chand Daga vs The Deputy Commissioner Of Income Tax

Bench: Rajasthan High Court - Jodhpur
Date: 20 November 2025
Sections engaged: 132, 132A, 148, 151A, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed D.B. Civil Writ Petition No. 22850/2025 before the Rajasthan High Court. Per the source preview, counsel submitted that the controversy was squarely covered by the Jaskaran Singh Brar judgment (D.B. Civil Writ Petition No. 18987/2025, dated 24.09.2025), which reproduced the Gujarat High Court's holding in Talati and Talati LLP that the notification dated 29th March 2022 prescribing the e-assessment scheme does not cover a case where a notice under Section 148 is issued by the JAO on information received in the matter of search and seizure under Section 132, or requisitioned under Section 132A; the Gujarat High Court had relied on Explanation 2 to Section 148 as it existed at the relevant time.

Patterns across these 12 rulings

JAO vs. FAO jurisdiction is the dominant Rajasthan HC theme. Seven of the eight High Court matters in this set (cases 5, 7, 8, 9, 10, 11, 12) centre on the same legal question: whether a notice under Section 148 issued by the Jurisdictional Assessing Officer (JAO) — rather than a Faceless Assessing Officer — is valid in cases where the information originated from a search or requisition under Sections 132 or 132A. The Rajasthan High Court Jodhpur bench treated this as a settled, recurring controversy across all these petitions.
Reliance on a single anchor precedent across multiple HC petitions. Cases 7, 11, and 12 each expressly invoke the same co-ordinate Bench judgment — Jaskaran Singh Brar vs. Principle Commissioner of Income Tax (Central) Jaipur & Ors. (D.B. Civil Writ Petition No. 18987/2025, dated 24.09.2025) — as the controlling authority. This pattern of short "covered-by" orders disposing of fresh petitions by reference to an anchor ruling is visible across at least five of the eight HC matters.
Section 132A and Section 132 consistently co-cited. In every case in this compilation, Section 132A appears alongside Section 132. This reflects the legal reality that requisition under Section 132A triggers the same downstream assessment machinery — particularly Section 153A — as a conventional search and seizure, making both provisions unavoidable reference points in the same proceedings.
Section 153A as the downstream assessment vehicle in search matters. Sections 153A (and in some cases 153C) appear as sections engaged in the ITAT matters (cases 1, 2, 4) and in all the HC writ petitions. This confirms that the compilation uniformly concerns the post-search assessment framework rather than regular scrutiny or standalone reassessment.
ITAT matters present more varied substantive grounds. While the HC matters cluster tightly around the JAO/FAO jurisdiction point, the ITAT matters (cases 1, 2, 3, 4, 6) engage a wider range of issues — including penalty proceedings, unexplained cash credits, reassessment after information from financial data, and search-related additions — reflecting the more fact-intensive adjudication that takes place at the Tribunal level after first appeals.

How to use this compilation

This index should serve as a structured starting point, not an end point. Each entry provides the tribunal or court, the date, the sections engaged, and a brief procedural note derived exclusively from the available source preview. Because several source previews in this set are procedural or introductory in nature — capturing only the caption, parties, bench composition, and opening paragraphs — the substantive reasoning of the full judgment is not always reflected here. Researchers should always retrieve and read the complete, signed order before drawing any conclusions about the legal position in a given case.

Before relying on any ruling listed here, verify whether the order has been appealed, stayed, overruled, or distinguished by a later judgment. The Rajasthan High Court matters in particular reference an evolving line of authority flowing through co-ordinate bench decisions; subsequent Division Bench or Supreme Court orders may have altered the landscape. Parallel CBDT instructions, circulars, or notifications — including any amendments to the e-assessment scheme or faceless-assessment framework — should also be checked, as several of the HC matters directly turn on the interaction between statutory provisions and delegated-legislation notifications.

For the ITAT matters, the normal appellate hierarchy (ITAT → High Court → Supreme Court) applies. Check the respective High Court cause lists to confirm whether any of the ITAT orders indexed here have been challenged under Section 260A or by way of writ. ITA numbers and PAN values cited in this index are drawn directly from the source previews and should be treated as reference identifiers only, to be confirmed against the official court record.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Sections 153A & 132A Search Assessments: 12 ITAT and HC Rulings (2025–2026)