[2025:RJ-JP:38031-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 269/2023 Late Shri Nand Kishore Khandelwal, Through Legal Heir Shri Rajesh Kumar Gupta S/o Late Shri Nand Kishore Khandelwal, Aged About 51 Years, R/o 2A-98, Subhash Colony, Shastri Nagar, Jaipur 302016, Rajasthan. ----Petitioner Versus 1. Income Tax Officer, Ward 4 (2), Jaipur, Ncr Building, Statue Circle, Jaipur. 2. Union Of India, Through Finance Secretary, Ministry Of Finance (Department Of Revenue), Central Board Of Direct Taxes, North Block, New Delhi 110002 ----Respondents For Petitioner(s) : Mr. Kanishk Singh, Adv. & Mr. Aditya Bohra, Adv. on behalf of Mr. Gunjan Pathak, Adv. For Respondent(s) : Ms. Jaya P Pathak, Adv. on behalf of Mr. Sandeep Pathak, Adv. HON'BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE SANJEET PUROHIT Order 17/09/2025 1. Both the learned counsels ad idem clearly state that the issue raised in the present writ petition stands finally adjudicated by the Hon’ble Supreme Court in Union of India vs Rajeev Bansal, SC 2024 INSC 754 wherein, the Hon’ble Supreme Court held as under:- “112. Let us take the instance of a notice issued on 1 May 2021 under the old regime for a relevant assessment year. Because of the legal fiction, the deemed show cause notices will also come into effect from 1 May 2021. After accounting for all the exclusions, the assessing officer will have sixty-one days [days between 1 May 2021 and 30 June 2021] to issue a notice under [2025:RJ-JP:38031-DB] (2 of 2) [CW-269/2023] Section 148 of the new regime. This time starts ticking for the assessing officer after receiving the response of the assessee. In this instance, if the assessee submits the response on 18 June 2022, the assessing officer will have sixty-one days from 18 June 2022 to issue a reassessment notice under Section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under Section 148 of the new regime will end on 18 August 2022.” 2. Keeping in view the above, the present writ petition stands dispose of, in the aforesaid terms mutatis mutandis 3. All pending application(s), if any, stand disposed of. (SANJEET PUROHIT),J (SANJEEV PRAKASH SHARMA),J HEENA/MAHIMA/95