Order : 1. Mr. Gunjan Pathak, counsel for petitioner submits that issue involved in this petition is squarely covered by order of Co- ordinate Bench of this Court in D.B. Civil Writ Petition No.14638/2022 (Rajesh Sharma Versus Income Tax Officer Anr.) and other connected matters, passed on 21 st August 2025. 2. Order dated 21 st August 2025 reads as under: “1. This bunch of writ petitions was tagged together solely on account of one common issue involved with regard to the validity of notices issued under Section 148 of the INCOME TAX ACT , 1961 (for brevity, 'the Act'), and the effect of TOLA and Finance Act, 2021, bringing the new faceless regime. 2. In the present bunch of the petitions, counsels for the petitioners have submitted that in terms of the judgment passed by the Supreme Court in the case of Union of India Vs. Rajeev Bansal (SC), 2024 INSC, 754 , in some of the cases, notices issued to them under Section 148 of the Act, have become time barred and the proceedings required to be dropped. In some of the other cases, the proceedings would continue and the authorities can proceed, while in some other cases, the valuation being less than Rs.50,00,000/- (Rs. Fifty Lakhs), the proceedings required to be dropped as per the stand taken by the revenue before the Supreme Court. There is one other argument which is advanced before this Court with respect to the notices having been issued during the period by the Jurisdictional Assessing Officer (JAO). 3. Learned counsels have submitted that such notices would be bad in law, in view of the new faceless regime having come into force. However, in the case of M/s Patran Foods Pvt. Ltd. Vs. Union of India & Ors ., decided on 20.12.2024, one of us (Mr. Sanjeev Prakash Sharma, J.) has taken this view while sitting in Punjab and Haryana High Court which reads as under: “18. The Supreme Court while examining the interplay of Ashish Aggarwal with TOLA in Rajeev Bansal's case (supra) had noticed one instance in para 113. It used the words 'to assume jurisdiction to issue notices under Section 148 with respect to the relevant assessment years of 2013-2014, 2014-2015, 2015-2016, 2016-2017 and 2017-2018'. The Supreme Court while examining the interplay of Ashish Aggarwal with TOLA in Rajeev Bansal's case (supra) had noticed one instance in para 113. It used the words 'to assume jurisdiction to issue notices under Section 148 with respect to the relevant assessment years of 2013-2014, 2014-2015, 2015-2016, 2016-2017 and 2017-2018'. It had to be within the time prescribed under Section 149(1) of the new regime read with TOLA and also obtain the previous approval of the authority under Section 151 of the Act. It observed that the notice issued without complying with the preconditions is invalid as it affects the jurisdiction of the assessing officer. Thus, the new scheme has been allowed to operate so far as the procedure part is concerned. However, the Apex Court has no occasion to examine the jurisdiction of the assessing officer with respect to Section 124 of the Act as after the new scheme having been introduced on 29.03.2022, the jurisdiction to make assessment and reassessment has been transferred to the faceless authority. We will have to examine as to whether a notice which was originally issued by the Jurisdictional Assessing Officer in terms of the old regime and which has been deemed to be issued under Section 148 B of the Act can be allowed to be processed by the same officer or not. 19. The entire scheme of the Act specifically requires the same assessing officer, who issues notices to conduct an enquiry and considered their reply in terms of Section 148 A. Thereafter, the same assessing officer is required to pass an order under the new scheme after giving notice under Section 148 of the old Act. In our considered opinion, if we examine the provisions of present situation, which has arisen on account of treating the notices issued under Section 148 of the Act as notice under Section 148 A(b) of the Act, the natural corollary would be that such replies which may be received to the notice issued under Section 148 A(b) of the Act, would be examined by the same assessing officer, who had originally issued the notices under the old regime. His jurisdiction cannot be said to have been taken away for examining the reply to notice under Section 148 A(b) of the Act. His jurisdiction cannot be said to have been taken away for examining the reply to notice under Section 148 A(b) of the Act. Therefore, as a result the same assessing officer i.e. JAO would be also entitled to take a decision on such reply and pass orders of assessment or reassessment in terms of the new provisions of Section 148 of the Act. 20. In Rajeev Bansal's case (supra) , the Apex Court took into consideration the said aspect and held that the revenue shall after receiving the response of the assessee, consider the reply in terms of Section 148 A(c) of the Act and take a decision under Section 148 A(d) of the Act. The scheme of the new provisions also reflect that it is the assessing officer, who has issued notices, would take a decision under Section 148 A(d) of the Act as it is he who would be having the available material to examine the reply of the assessee. He would thereafter issue notice under Section 148 of the Act treating it to be a fit case for reassessment, if so required or may drop the proceedings. Once he has issued notice under Section 148 of the Act, the proceedings can be transferred for issuing the reassessment order through faceless regime. If the contention of the respondents is accepted, the entire process has to be conducted under the faceless regime, not by the jurisdictional assessing officer the result would be that all the notices issued and treated by the Supreme Court as issued under Section 148 A(b) of the Act would become otiose and redundant for all the purposes. 21. As per Section 148 of the Act amended with effect from 01.04.2021, the assessing officer has to serve on the assessee a notice before making assessment/reassessment or recomputation on the basis of information with the assessing officer which suggests that the income chargeable to tax has escaped assessment. Therefore, the assessing officer has to be the same who had initiated the proceedings since originally the jurisdictional assessing officer had issued the notice which has been deemed to be a notice under Section 148 A(b) of the Act by the Apex Court. Therefore, the assessing officer has to be the same who had initiated the proceedings since originally the jurisdictional assessing officer had issued the notice which has been deemed to be a notice under Section 148 A(b) of the Act by the Apex Court. It can be safely assumed that it is the same assessing officer who is required to issue notice under Section 148 of the Act and also to pass order of assessment/ reassessment or recomputation in terms of Section 147 of the Act. 22. We find that as per Section 144B (7) and (8) of the Act (supra), the Principal Chief Commissioner or the Principal Director General, as the case may be, in-charge of the National Faceless Assessment Centre, may in facts and circumstances as laid down therein or at any stage of assessment transfer the case to the assessing officer having jurisdiction over the case. This power, of course, has to be exercised in circumstances laid down therein. 23. Although, we find that the power under Section 144B (7) and (8) has not been exercised by the Principal Chief Commissioner to the Jurisdictional Assessing Officer, however, the circumstances have been considered by the Supreme Court while exercising its power under Article 142 of the Constitution of India in Ashish Aggarwal's case (supra), whereby it has specifically provided the jurisdiction to the Jurisdictional Assessing Officer by deemed fiction of law under the new Faceless Regime. We say so because the initial notice was issued by the Jurisdictional Assessing Officer, which has been treated to be a notice under Section 148 A of the Act and Section 148 of the old Act, as notices under Section 148 A(a) and (b) of the Act. He would, therefore, be the best person to assess and re-assess the provisions of law are required to be otherwise considered strictly. However, in cases where there is an allegation of escape of income, on account of which notices were issued by the Jurisdictional Assessing Officer, must reach to its logical conclusion by the same officer. We, therefore, hold that the Jurisdictional Assessing Officer would continue to proceed and have jurisdiction to decide the notices which were originally issued by him. 24. In the opinion of this Court, the procedure which has been laid down under the new regime will of course have to be followed by the Jurisdictional Assessing Officer. 25. We, therefore, hold that the Jurisdictional Assessing Officer would continue to proceed and have jurisdiction to decide the notices which were originally issued by him. 24. In the opinion of this Court, the procedure which has been laid down under the new regime will of course have to be followed by the Jurisdictional Assessing Officer. 25. We find that no prejudice would be caused if such a course is adopted by the Jurisdictional Assessing Officer. The submission of the petitioners is, therefore, found to be without force. 26. In view of our above reasons and observations, we do not agree with the view taken by the Telangana High Court in Kankanala Ravindra Reddy's case (supra) 27. The contention of Mr. Bansal, learned senior counsel for the petitioners relating to non-application of the judgment passed in Rajeev Bansal's case (supra) is also found to be wholly misconceived. So far as the case decided by us in Jasjit Singh's case (supra) is concerned, we find the facts of that case were different. The case deals with the notices which have been issued by the Jurisdictional Assessing Officer after the faceless regime had come into force with effect from 29.03.2022. 28. The view taken by the Bombay High Court in Hexaware Technologies Limited's case (supra) also does not apply to the present bunch of cases. It is made clear that the petitioners relating to the orders passed by the Assessing Officer on merits can be raised in appeal before the appellate authority. If appeals are so filed, the same shall be decided on merits and the delay shall be condoned on account of the fact that the writ petitions are pending before this Court.” 4. The counsels appearing for the revenue submit that in each case facts will have to be examined individually. 5. We accordingly direct the revenue to examine each and every case relating to the deemed notices issued under Section 148 of the Act, in light of the observations made by the Supreme Court in Rajeev Bansal's case (supra) and reach to a conclusion, as to whether the proceedings would fall within the limitation or have become time barred in terms of sub-para F, G & H of paragraph No.114 (supra). 6. 6. While examining the cases, the example as mentioned by the Apex Court in its judgment in Rajeev Bansal’s case (supra) in paragraph No.112 and observations made in paragraph Nos.110 and 111, shall also be taken into consideration. Cases, which fall less than the value of Rs.50,00,000/- would have to be dropped keeping in view the stand taken by the revenue before the Apex Court, as observed in paragraph No.53. 7. The aforesaid exercise shall be conducted by the concerned competent Officer of the Department expeditiously, preferably, within a period of two months without any further delay. The decision shall be conveyed to the assessee in terms of the faceless regime by the concerned Officer keeping in view the provision of Section 144-B of the Act. 8. In view of the above, the contentions raised before us are rejected. Further, it has also been brought to notice that in the recent judgments passed in the cases of Assistant Commissioner of Income Tax Vs. Vikram Kapahi, reported in [2025] 170 taxmann.com 593 (SC) , decided on 06.01.2025, Income Tax Officer Vs. Ashish Acharatlal Varaiya, reported in [2024] 168 taxmann.com 588 (SC) and Income Tax Officer Vs. Pradeep Himatlal Shah , reported in [2025] 170 taxmann.com 472 (SC) , decided on 20.12.2024, the Hon’ble Supreme Court has also disposed of the Special Leave Petitions in terms of the judgment passed in Rajeev Bansal (supra) with the observation that the Assessing Officer shall dispose of the petitions in terms of the law laid down therein. 9. We order accordingly. All the petitions stand disposed of. Pending application, if any, also stands disposed of. 10. If any of the petitioner/assessee is still aggrieved of the order passed, remedy in terms of the provision of the Act can be availed by him. 11. A copy of this order be placed in each connected file. D.B. Civil Writ Petition Nos.16013/2022, 16144/2022 & 16705/2022:- 1. In view of the decision which has been taken in D.B. Civil Writ Petition No.14638/2022 and other connected matters (supra), we hold that in cases where the assessee have gone in the appeal against the final assessment order, the said appeals would stand decided in view of the observations and findings arrived at herein above. The writ petitions are disposed of, accordingly. 2. A copy of this order be placed in the above three writ petitions.” 3. Mr. The writ petitions are disposed of, accordingly. 2. A copy of this order be placed in the above three writ petitions.” 3. Mr. Sandeep Pathak, counsel for respondents agrees. 4. Ordered accordingly. 5. Petition disposed. 6. All interim applications, if any, also stand disposed.