[2026:RJ-JP:7607-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 2010/2026 Abhimanyu Golcha Son of Shri S.K. Golcha, Aged About 44 Years, R/o B-40, Golcha Square, Sardar Patel Marg, Jaipur 302001 Through His Authorized Signatory Shri Deepak Gangwal S/o Shri Ramesh Kumar Gangwal, Aged About 43 Years, Resident of T-2, Third Floor, Shri Sai Residency, Laxmi Nagar, Mansarovar Jaipur 302001. ----Petitioner Versus Assistant Commissioner of Income Tax, Central Circle-4, Jaipur Having Its Address At 4Th Floor, Jeevan Nidhi-2, LIC Building, Ambedkar Circle, Jaipur. ----Respondent For Petitioner(s) : Mr. Rohan Chatter with Mr. N.K. Jain on behalf of Mr. Siddharth Ranka For Respondent(s) : Ms. Tanushka Saxena on behalf of Mr. Siddharth Bapna HON'BLE THE ACTING CHIEF JUSTICE MR. SANJEEV PRAKASH SHARMA HON'BLE MRS. JUSTICE SANGEETA SHARMA Order 18/02/2026 1. This writ petition under Article 226 of the Constitution of India has been filed seeking the following reliefs as under: “1. quashing & setting aside the impugned notice dated 05.02.2025 (Annexure 2) issued under section 153C of the Act, the impugned order dated 03.12.2025 (Annexure 5) disposing the objections raised by the petitioner & the impugned reassessment order dated 16.12.2025 (Annexure 7) for A.Y. 2014-15 and all consequential orders / proceedings initiated in pursuance thereto as illegal and void; [2026:RJ-JP:7607-DB] (2 of 3) [CW-2010/2026] 2. direct that the costs of this petition be awarded to the petitioner and pass such other or further orders as deemed just and proper in the facts and circumstances of the case.” 2. Learned counsel for the petitioner submits that the controversy involved in the present matter is under consideration before the Hon’ble Apex Court in Siddharth Totuka Vs. Assistant Commissioner of Income Tax Central Circle in SLP No. 31711/2025, in which the following order was passed on 08.12.2025: “1. Issue notice. 2. Dasti service, in addition, is permitted. 3. Tag with SLP(C) No. 33392 of 2025. 4. In the meantime, the proceedings before the Adjudicating Authority shall remain stayed insofar as Section 153C of the Income Tax Act, 1961 is concerned including the order impugned passed by the High Court.” 3. Learned counsel for the petitioner submits that the proceedings before the Adjudicating Authority, insofar as they pertain to Section 153C of the Income Tax Act, 1961, including the impugned order under consideration before this Hon’ble Court in the present case, have been stayed by the Hon’ble Apex Court. It is, therefore, prayed that similar protection be extended in the present petition as well. Learned counsel further fairly submits that the outcome of this petition shall be governed by the outcome of the said SLP and, thus, subject to such outcome, the petition may be disposed of while extending the aforesaid protection. 4. Learned counsel for the respondent fairly submits that the order passed by the Hon’ble Apex Court shall be duly followed. He further submits that in the event this petition is disposed of, the [2026:RJ-JP:7607-DB] (3 of 3) [CW-2010/2026] same may be made subject to the final outcome of the aforesaid SLP. 5. Having considered the submissions made at the Bar, this Court is of the clear opinion that once the narrow compass of the issue is being directly adjudicated by the Hon’ble Apex Court in pursuance of the litigation undergone by the parties pertaining to Section 153C of the Income Tax Act, 1961, it would be appropriate to dispose of the present writ petition by extending the same protection as granted by the Hon’ble Apex Court. 6. Accordingly, it is directed that the Adjudicating Authority shall not proceed with any proceedings under Section 153C of the Income Tax Act, 1961 against the petitioner, as also consequential order(s), if any, including giving effect to any impugned orders, for so long as the interim protection granted by the Hon’ble Apex Court continues to operate. The outcome of SLP No. 31711/2025 (tagged with SLP(C) No. 33392/2025) shall govern the outcome of the present petition. 7. The instant writ petition is disposed of accordingly. 8. Pending application(s), if any, shall also stand disposed of. (SANGEETA SHARMA),J (SANJEEV PRAKASH SHARMA),ACTING CJ KAVISH /16