This compilation indexes twelve writ petition rulings decided by various High Courts across India between November 2025 and August 2026, each engaging Section 148A(1) of the Income Tax Act, 1961. The cases originate from the Bombay, Telangana, Gujarat, Calcutta, and Karnataka High Courts and collectively illustrate the range of procedural and substantive challenges that taxpayers — individuals, partnerships, and corporates — have brought against show-cause notices and consequential reassessment orders issued under the Section 148A framework. The compilation is intended for use by in-house tax teams, Big-4 associates, and legal researchers who need a structured, court-wise reference point for this evolving area.

Research index only. This page catalogues court proceedings for informational and research purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation to take any particular course of action. Readers should verify all information against the full text of the relevant judgment and consult qualified legal or tax professionals.

The statutory framework in one paragraph

Section 148A of the Income Tax Act, 1961 — introduced with effect from 1 April 2021 as part of the Finance Act 2021 reassessment reforms — prescribes a mandatory pre-notice procedure before a notice for reassessment under Section 148 can be issued. Section 148A(1) specifically requires the Assessing Officer to conduct an inquiry, if considered necessary, and to provide the assessee with an opportunity of being heard by way of a show-cause notice before any order under Section 148A(3) is passed. Section 148A(3) requires the Assessing Officer to pass an order on the show-cause notice, and only thereafter — where the AO concludes that a case for reassessment is made out — may a notice under Section 148 be issued. The procedural sequence is therefore: inquiry (if any) → show-cause notice under Section 148A(1) → reply by assessee → order under Section 148A(3) → notice under Section 148. Challenges to any step in this chain have generated a significant body of High Court writ jurisprudence, twelve rulings from which are indexed below.

The 12 rulings

1. Manoj Shivraj Anchalia vs The Assisstant Commissioner Ofin Come

Bench: Bombay High Court
Date: 17 August 2026
Sections engaged: 139, 148, 148A(1), 148A(3), 80G
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 3658 of 2026) was filed before the Bombay High Court seeking to quash and set aside the notice dated 29th June 2026 issued under Section 148, the order dated 29th June 2026 passed under Section 148A(3), and the show-cause notice dated 27th March 2026 issued under Section 148A(1). Per the source preview, one of the issues raised in the show-cause notice related to a deduction of Rs. 8,00,000/- which the petitioner's counsel submitted had been missed due to an inadvertent mistake, and an additional tax payment was stated to have already been made thereafter. The appeal was filed against the full chain of reassessment action — the Section 148A(1) show-cause notice, the Section 148A(3) order, and the Section 148 notice — and the matter was heard before the court on 17 August 2026.

2. Nitin Enterprises vs Income-Tax Officer Ward - 5(1)

Bench: Telangana High Court
Date: 11 August 2026
Sections engaged: 132, 143(1), 148, 148A, 148A(1), 148A(3), 151, 152(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (WP No. 24088 of 2026) was filed under Article 226 of the Constitution of India before the Telangana High Court by a partnership firm engaged in the business of trading in electrical fittings and retail, having its office at Hyderabad. Per the source preview, the Jurisdictional Assessing Officer issued a show-cause notice dated 26.03.2026 under Section 148A(1) for the assessment year 2024-25, thereafter passed an order dated 24.06.2026 under Section 148A(3), and consequently issued a notice on the same date i.e. 24.06.2026 under Section 148. The petition also raised a question concerning the role of the authority described as the specified authority under Section 151, and the matter was disposed of on 11 August 2026.

3. Pradipkumar Vallabhdas Joisar vs Income Tax Officer Ward 1 (3) (1)

Bench: Gujarat High Court
Date: 16 July 2026
Sections engaged: 148A(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/SCA No. 9514 of 2026) was filed before the Gujarat High Court at Ahmedabad. Per the source preview, the controversy arising in the petition was described as being in narrow compass, and with the consent of the advocates for the respective parties, the matter was taken up for hearing at the final stage. The appeal was filed against proceedings initiated under Section 148A(1) and Section 148A(3), and the matter was decided on 16 July 2026 as an oral judgment.

4. Dhruv Vijaykumar Trivedi vs Deputy Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 9 April 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/SCA No. 4948 of 2026) was filed before the Gujarat High Court at Ahmedabad, challenging proceedings under Section 148A(1), Section 148A(3), and Section 148. Per the source preview, the matter was heard as an oral judgment on 9 April 2026 before the bench; the text_preview is substantially composed of repeated neutral citation headers and does not disclose additional substantive ground beyond the formal listing of appearances and the writ proceeding's existence.

5. Deep Vijaykumar Trivedi vs Deputy Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 7 April 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/SCA No. 4515 of 2026) was filed before the Gujarat High Court at Ahmedabad challenging proceedings under Section 148A(1), Section 148A(3), and Section 148. Per the source preview, the controversy arising in the petition was described as being in narrow compass, and with the consent of the advocates for the respective parties, the matter was taken up for hearing. The matter was decided as an oral judgment on 7 April 2026, approved for reporting.

6. Gulbrandsen Private Limited vs Dy. Commissioner Of Income Tax, Circle

Bench: Gujarat High Court
Date: 24 February 2026
Sections engaged: 148A(3), 148A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/SCA No. 15851 of 2025) was filed before the Gujarat High Court at Ahmedabad. Per the source preview, the petitioner assailed a notice dated 16.06.2025 (the relevant provision under which the notice was issued is cut off in the preview), and since a short issue was involved, the matter was taken up for final hearing on the day with the consent of the advocates for the respective parties. The petition engaged Section 148A(3) and Section 148A(1), and the oral judgment was delivered on 24 February 2026, approved for reporting.

7. Perin Exim Llp vs Income Tax Office - Ward 2(3)(6), Surat

Bench: Gujarat High Court
Date: 23 February 2026
Sections engaged: 148A(1), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was heard as a common oral order (R/SCA No. 14142 of 2025, along with SCA Nos. 14589 of 2025 and 17050 of 2025) before the Gujarat High Court. Per the source preview, a common issue was involved in the writ petitions relating to the service of the notice issued by the Assessing Officer under Section 148A(1) of the Income Tax Act, 1961, and SCA No. 14142 of 2025 was the lead matter. The petitioner raised a case relating to the notice under Section 148 which was dispatched through speed post (the preview is cut off), and the matter was taken up for final hearing on 23 February 2026.

8. Vijaykumar Jitendrakumar Trivedi vs Income Tax Officer, Ward 3(3)(5)

Bench: Gujarat High Court
Date: 10 February 2026
Sections engaged: 148A(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/SCA No. 13093 of 2025) was filed before the Gujarat High Court at Ahmedabad challenging proceedings under Section 148A(1) and Section 148A(3). Per the source preview, the controversy arising in the petition was described as being in narrow compass, and with the consent of the advocates for the respective parties, the matter was taken up for hearing. The matter was decided as an oral judgment on 10 February 2026, approved for reporting.

9. Haldia Petrochemicals Limited vs Assistant Commissioner Of Income Tax

Bench: Calcutta High Court
Date: 20 January 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WPO/753/2025) was filed before the Calcutta High Court challenging reassessment proceedings initiated by a notice dated June 25, 2025 under Section 148, preceded by an order dated June 25, 2025 under Section 148A(3) and a show-cause notice dated March 19, 2025 under Section 148A(1). Per the source preview, the proceedings were aimed at reassessing the petitioner's income for the assessment year 2019-20; the show-cause notice alleged that the petitioner had entered into transactions with an entity described as Padmey Impex Private Limited, which was alleged to have siphoned funds using fake invoices and lorry receipts across several bank accounts.

10. Sri Vinayak Ramachandragouda Neelgund vs The Income Tax Officer

Bench: Karnataka High Court
Date: 11 December 2025
Sections engaged: 148, 148A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 105471 of 2025) was filed before the Karnataka High Court at the Dharwad Bench under Article 226 of the Constitution of India seeking a writ of certiorari or other appropriate writ to quash an impugned notice bearing a DIN and notice number referencing Section 148. Per the source preview, the petition was filed against a notice issued under Section 148 and engages Section 148A(1), and the petitioner was represented through an authorised representative. The matter was heard and decided on 11 December 2025.

11. Smt. Benitha Mary vs Income Tax Officer

Bench: Karnataka High Court
Date: 10 November 2025
Sections engaged: 148A(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 33394 of 2025) was filed before the Karnataka High Court at Bengaluru under Article 226 challenging proceedings under Section 148A(1) and Section 148A(3). Per the source preview, the petitioner is stated to be a resident of California, USA, represented through a constituted attorney in Bengaluru, and multiple Income Tax Officers including one in the International Taxation Ward were named as respondents along with the National Faceless Assessment Centre. The matter was heard and decided on 10 November 2025.

12. M/S Shree Stone Crushers vs The Assessment Unit

Bench: Karnataka High Court
Date: 3 November 2025
Sections engaged: 148, 148A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 108022 of 2025) was filed before the Karnataka High Court, Dharwad Bench under Articles 226 and 227 of the Constitution of India, seeking a writ of certiorari or direction in the nature of certiorari to quash notices dated 29.06.2025 issued under Section 148. Per the source preview, the respondents included the Assessment Unit of the National Faceless Assessment Centre, the local Income Tax Officer Ward-2 Belagavi, and the Joint Commissioner of Income Tax, Belagavi. The petition engages Section 148 and Section 148A(1), and the matter was heard and decided on 3 November 2025.

Patterns across these 12 rulings

Uniform procedural chain challenged. Across all twelve cases, petitioners challenge the same statutory sequence: a show-cause notice under Section 148A(1), followed by an order under Section 148A(3) (where applicable), followed by a notice under Section 148. The consistency of this challenge pattern across Bombay, Telangana, Gujarat, Calcutta, and Karnataka High Courts reflects the procedural architecture of the post-2021 reassessment regime and the frequency with which the full chain is contested in a single writ.
Gujarat High Court volume. Six of the twelve rulings originate from the Gujarat High Court (cases 3 through 8), suggesting a particularly active volume of writ litigation in that jurisdiction over this period. Several of these Gujarat matters were described in the source previews as involving controversies "in narrow compass," taken up for final hearing with the consent of both sides — indicating that at least some were disposed of relatively swiftly.
Multi-party and batch petitions. Case 7 (Perin Exim LLP) was heard as a common oral order consolidating three Special Civil Applications, each raising a common issue relating to service of a notice under Section 148A(1). This batch-filing pattern suggests that procedurally similar challenges are being consolidated before the same bench, a practice that may be emerging across jurisdictions.
Diverse taxpayer profiles. The petitioners span a wide range of taxpayer categories: individuals (cases 1, 3, 4, 5, 8, 10, 11), a partnership firm (case 2), a limited liability partnership (case 7), a private limited company (case 6), a large petrochemical corporate (case 9), and a stone-crushing firm (case 12). This breadth indicates that Section 148A(1) challenges are not confined to any particular class of taxpayer.
Faceless assessment infrastructure as respondent. In at least cases 11 and 12, the National Faceless Assessment Centre is named as a respondent alongside the local assessing officer and jurisdictional commissioner, reflecting the parallel jurisdictional structure created by the faceless assessment regime and the procedural questions this raises in reassessment proceedings.

How to use this compilation

This index is a starting point for legal and tax research, not a substitute for reading the full text of each judgment. Each entry above is derived from the available source preview and authoritative identity fields; in several cases the preview is limited to the cause title, appearances, and opening paragraphs of the order, which means the final holding, operative directions, and full reasoning are not captured here. Researchers must retrieve the complete judgment — from indiankanoon.org, the relevant High Court portal, or the official court record — before relying on any ruling for any purpose.

Before citing any of these rulings in a submission, brief, or advisory, researchers should also verify whether the order has been stayed, reversed on appeal, or distinguished in a subsequent proceeding. High Court writ orders in tax matters are frequently subjected to stays by division benches or the Supreme Court, and the status of a ruling can change materially after the date of the original order. Where a ruling is approved for reporting (as noted in several Gujarat High Court previews), it may carry greater persuasive weight, but this too should be confirmed from the official record.

Finally, researchers should cross-check any applicable CBDT circulars, instructions, and Finance Act amendments that may bear on the procedural questions raised in these cases. The reassessment framework under Sections 147–151 has been subject to ongoing legislative and administrative modification since the Finance Act 2021, and the validity of any notice or order will turn on the specific statutory provisions, CBDT instructions, and limitation periods in force at the relevant assessment year. Parallel proceedings, if any, should also be identified before relying on a single ruling in isolation.

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.

Section 148A(1) Show-Cause Notices: 12 High Court Writ Rulings (2025-2026)