Supreme Court to hear Centre's plea on I-T reassessment order

New Delhi: The Supreme Court agreed to hear on Friday the government's appeal challenging a Punjab and Haryana High Court order, which struck down Section 147A of the Income Tax Act concerning the jurisdiction of the assessing officer in reopened assessments.

The section, introduced by the Finance Act, 2026 to retrospectively amend the law, clarified that from April 1, 2021, jurisdictional assessing officers (JAOs), not the faceless system, were the authority to issue reassessment notices. The matter concerns reassessment proceedings involving more than 200,000 taxpayers.

The high court in its September 10 judgment held that the retrospective provision could not validate reassessment notices issued by JAOs when the faceless reassessment scheme was in effect. It quashed a batch of reassessment tax notices issued to assessees, holding that these notices were not issued through the process of randomised allocation of assessing officers and in a faceless manner. It held that reassessment proceedings begun by JAOs in breach of the faceless procedure were invalid.


While seeking urgent hearing on the appeal against the HC's judgement, additional solicitor general N Venkataraman told a bench led by CJI Surya Kant that the HC decision created a "huge vacuum in law".