[2025:RJ-JP:37760-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 12450/2025 Mahendra Verma S/o Late Kanhaiyalal Verma, Aged About 73 Years, R/o A-207-208, Nagar Residency, Near Rungta Hospital, Malviya Nagar, Jaipur 302017, Through Power Of Attorney Holder Vinod Bamalwa, Son Of Late Madan Lal Bamalwa, Aged About 51 Years, Residing At 9/1 Lower Rawdon Street, L.R. Sarani S.O. Kolkata West Bengal 700020. ----Petitioner Versus Assistant Commissioner Of Income Tax, Central Circle 4 Jaipur, Income Tax, New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondent For Petitioner(s) : Mr. Sanjay Jhanwar, Sr. Advocate assisted by Mr. Prakul Khurana and Mr. Rajat Sharma For Respondent(s) : Mr. Siddharth Bapna with Mr. Meyhul Mittal HON'BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE SANJEET PUROHIT Order 16/09/2025 1. The challenge is to the notice issued under Section 153(C) of the Income Tax Act, 1961 dated 16.01.2025 for the Assessment Year 2014-2015 and the disposal of the objections against reassessment proceedings order dated 14.07.2025. 2. Learned Senior Counsel appearing for the petitioner has vehemently argued that the notice was not maintainable against the petitioner under Section 153(C) and twin satisfaction of the AO were not recorded. He has also raised other ancillary arguments. We notice that the petitioner had earlier preferred a [2025:RJ-JP:37760-DB] (2 of 2) [CW-12450/2025] writ petition No.2386/2022, wherein he challenged the proceedings initiated under Section 148 against the argument advanced that the proceedings should have been initiated under Section 153(C). Accordingly, this Court quashed the proceedings initiated under Section 148 of the Income Tax Act vide judgment dated 19.03.2024 with liberty to the authorities to proceed against the writ petitioner in accordance with law. Since, the Court granted permission to the respondent- Tax Authorities to proceed, the challenge on the ground of limitation would not arise, now as it was at the instance of the petitioner that the order was passed by this Court granting liberty to the authorities to proceed. 3. In view thereto, the proceedings initiated against the petitioner under Section 153(C) cannot be objected, the objections have been rightly rejected by the authorities. 4. We, therefore, do not find any reason to interfere with the notice issued under Section 153(C), however, the petitioner is free to take up all the necessary arguments and defence available to him before the authorities who would of course pass an appropriate speaking order. 5. With the aforesaid observations, the writ petition is dismissed. Pending appreciation(s), if any, also stands disposed of. (SANJEET PUROHIT),J (SANJEEV PRAKASH SHARMA),J GAURAV/AVINASH/18