M/S Balajee Loha Private Limited v. Union of India
Case brief
What is this about?
High Court of Chhattisgarh (Bilaspur); WPT bunch of 22 petitions; Justice Rakesh Mohan Pandey; decided 12.02.2026; neutral citation 2026:CGHC:7831 (NAFR). Subject: orders under Section 148(A)(d) of the Income Tax Act, 1961 rejecting objections to initiation of reassessment/reopening under Section 148 quashed; governed by Supreme Court decisions in Union of India vs. Ashish Agarwal (2022) 138 taxmann.com 64 and Union of India vs. Rajeev Bansal (2024) 167 taxmann.com 70 (SC) concerning Section 148 notices issued 01.04.2021-30.06.2021; fresh objections including jurisdictional objections to be filed within 90 days with opportunity of hearing; Rajeev Bansal paras 112-114 apply to belated Section 148(A)(d) orders; other remedies preserved; all petitions disposed of.
What did the court decide?
Quashing and setting aside of the orders passed under Section 148(A)(d) of the Income Tax Act, 1961 and consequential proceedings in all the matters; direction to the Assessing Officer to allow fresh objections (including jurisdictional ones) within 90 days, grant an opportunity of hearing and dispose of the objections in terms of the law laid down in Ashish Agarwal and Rajeev Bansal; observations in paragraphs 112-114 of Rajeev Bansal to apply to late Section 148(A)(d) orders; all other rights and remedies preserved except issues concluded in those judgments.