Neutral Citation No. - 2025:AHC:133893-DB Court No. - 3 Case :- WRIT TAX No. - 497 of 2023 Petitioner :- Jupiter Buildtech Private Limited Respondent :- Assistant Commissioner Of Income Tax And 2 Others Counsel for Petitioner :- Rahul Agarwal Counsel for Respondent :- A.S.G.I.,Gaurav Mahajan,Sudarshan Singh Hon'ble Shekhar B. Saraf,J. Hon'ble Praveen Kumar Giri,J. 1. Heard Sri Rahul Agarwal, learned counsel for the petitioner; Sri Navin Chandra Gupta, Sri Gopal Verma & Sri Sudarshan Singh, learned counsel for the respondent-Union of India and learned counsel Sri Gaurav Mahajan on behalf of the Income Tax Department. 2. It is to be noted that the petitioner has come before this Court primarily against the order passed under Section 148(A)(d) of the Income Tax Act, 1961, wherein its objections to the initiation of reassessment proceedings under Section 148 have been rejected. It is also to be noted that the Supreme Court in Union of India vs. Rajeev Bansal reported in (2024) 167 taxmann.com 70 (SC) and Union of India vs. Ashish Agarwal reported in (2022) 138 taxmann.com 64, has finally decided the issue with regard to the validity of notices issued under Section 148 of the Income Tax, 1961 from 1st April, 2021 till 30th June, 2021. 3. In light of the above, we are of the view that the orders passed under Section 148(A)(d) of the Income Tax, 1961, in all the above matters and any other consequential proceedings, are required to be quashed and set aside with a direction upon the Assessing Officer to allow the petitioner to once again file objections, and thereafter, dispose of the objections in terms of the law laid down by the Supreme Court in Ashish Agarwal (supra) and Rajeev Bansal (supra). The petitioner shall be at liberty to raise new objections, including jurisdictional ones and rely upon other judgments of the Apex Court as applicable. These objections should be filed by the petitioner within a period of four weeks. The authority shall thereafter grant an opportunity of hearing to the petitioner and pass orders in accordance with law. 4. We make it clear that the assessee shall also be at liberty to pursue all the rights and remedies in accordance with law, except the issues that have been concluded in the judgments of Ashish Agarwal (supra) and Rajeev Bansal (supra). 5. With regard to the orders passed under Section 148(A)(d) of the Income Tax Act, 1961 that may have been passed beyond time as observed by the Supreme Court in paragraphs 112, 113 and 114 of Rajeev Bansal (supra), we make it clear that the observations made therein shall apply. 6. With the above observations and directions, the writ petition is disposed of. Order Date :- 7.8.2025 DKS (Praveen Kumar Giri,J.) (Shekhar B. Saraf, J.) Digitally signed by :- DEEPAK KUMAR SRIVASTWA High Court of Judicature at Allahabad